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
Fighting for Compliance since 1976
Bankers' Threads User #8