The Fed included a provision in its last proposal to update Regulation CC. It would indemnify the bank that took the paper item for deposit and had it charged back as a duplicate presentment on the theory that the bank that accepts mobile deposits contributes to the risk of such events. But until the Fed makes a final rule change (is that EVER going to happen?) ....
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8