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?) ....
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8