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#2182298 - 06/19/18 04:23 PM availability schedule for mobile deposits
crc Offline
100 Club
Joined: May 2004
Posts: 150
South Dakota
What is the availability schedule requirement for mobile deposits?

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Deposits and Payments
#2182299 - 06/19/18 04:26 PM Re: availability schedule for mobile deposits crc
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 1,979
The West
What did you say in your mobile banking agreement?
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CRCM

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#2182303 - 06/19/18 04:33 PM Re: availability schedule for mobile deposits TryingtoComply
crc Offline
100 Club
Joined: May 2004
Posts: 150
South Dakota
It's a work in progress so I wanted to determine if there are any guardrails in Reg CC and the updates.

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#2182349 - 06/19/18 07:14 PM Re: availability schedule for mobile deposits crc
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,786
Cape Cod
Guardrails?

Three is nothing in Regulation CC currently or as amended effective July 1 that speaks to availability for mobile-deposited checks. Checks deposited by RDC and its younger cousin, mobile RDC (AKA mobile deposit or mRDC) aren't covered by the availability provisions of Regulation CC yet.

The Fed and the Bureau are expected to issue proposed amendments to subpart B of the regulation (funds availability and disclosures) that MAY bring RDC and mRDC deposited check images as regulated items. It seems reasonable to assume that they would be subject to the same availability rules as checks deposited "the old-fashioned way." There's no guarantee on WHEN that's likely to happen.

However, it would seem sensible, in the meantime, to make funds deposited via mRDC available using the same schedules you use for traditional check deposits.
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John S. Burnett
BankersOnline.com
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#2182656 - 06/21/18 07:04 PM Re: availability schedule for mobile deposits John Burnett
crc Offline
100 Club
Joined: May 2004
Posts: 150
South Dakota
Thanks. We had planned to use our traditional schedule.

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