What is the availability schedule requirement for mobile deposits?

What did you say in your mobile banking agreement?

It's a work in progress so I wanted to determine if there are any guardrails in Reg CC and the updates.

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.

Thanks. We had planned to use our traditional schedule.