I am disappointed.
But I shouldn't have expected more than what the Fed did. The new rule will be effective 7/1/18, and it will clean up a few issues. For example, it will clearly bring RDC and mRDC items under the Reg CC umbrella, and provide an indemnity for the depositary institution that takes a paper check for deposit after it's already been deposited via RDC or mRDC, UNLESS the check has a restrictive indorsement (such as "for mobile deposit only") inconsistent with the means of deposit on it. It will further persuade banks to send and accept return items electronically and will address "electronically created checks." It does not, however, do anything to remove all the "local check" and "nonlocal" check clutter in the regulation, or make any change in the current rules on delays in funds availability (statutory and exception holds) or disclosures. All of that awaits a meeting of the minds of the Fed and the Bureau which no one is making any encouraging noises about.
Perhaps the Fed's action in this chunk of the regulation will churn up some cooperative and creative juices within both the Fed and the Bureau to address "dropping the other shoe." On the other hand, we may just find that addressing this in smaller "chunks" makes the change management a bit easier.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8