Hello,

We have been seeing an uptick of fraud items coming thru our Mobile Deposit platform.

New accounts & some old ones. Are any of you handling the holds differently than what Reg CC allows?

thanks in advance for your input!

So you allow your customers continued access to mobile banking if they've tried to deposit a fraudulent check?

Our policy is to remove the customer's mobile banking rights immediately and sometimes even close the account.

Hello Sarah,

No, if there is fraud they are blocked from all electronic avenues and the accounts are closed.

What I'm looking for is input on holds for a mobile deposit. We follow all Reg CC rules but was curious if anyone knew if we could waiver from the traditional Reg CC rules on hold timeframes and hold items longer for mobile deposits?

thank you

Mobile deposits are not subject to Reg CC unless your mobile deposit agreement makes it so. If you wish to modify your agreement to hold funds longer, then you would need to notify all current users of the change in accordance with the terms of the existing agreement and any state law requirements.

Hello Brian,

This is very helpful!

Thank you

At some point, I expect the Fed to pull remote deposit images and mobile deposit images under the availability requirement of Reg CC. Given the Fed's abysmal sloth in getting the regulation updated, that could be some years from now, but it will come. But for now, Brian is right.

Thank you everyone for your input. This helps me tremendously!

We review most of our mobile deposits (mainly that they are endorsed properly) and if the account is new we will look at the activity. We've placed extended holds on any deposits that look suspicious and have caught a few fraudulent items (and closed the accounts)

We review most of ours as well for the same reasons. Still a couple have gotten thru.
Thanks for responding!

What is your reason for placing the hold?