i need your help again please.......We are just now beginning to offer RDC just to consumer accounts, not commercial. I'm a little confused on a few things:

We've been told that if we don't offer RDC to commercial customer's that we really aren't doing RDC? We would be doing mobile deposits, and we could just incorporate this language in our online banking policy?

Another party advised us to make sure we refer to RDC in our BSA policy?

Which policy or policies do we need to reference RDC in?

Any advice would be greatly appreciated.

If your bank would offer RDC as a service then yes it should be included in your BSA risk assessment.

Mobile deposit is generally considered a consumer product and we include the appropriate language in our online banking policy.

Me personally I would put RDC in a Commercial policy where ACH origination and other products set.

Mobile RDC may be scaled down from business RDC, but it's still RDC. You should have a completed risk analysis before offering the service and, because it affects to a limited extent your BSA AML risk, you should address RDC there, too.

thanks