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#2254786 - 06/03/21 02:16 PM Mobile Deposits & Extended Holds
cadym Offline
Member
Joined: Aug 2007
Posts: 51
Michigan
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!

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General Discussion
#2254793 - 06/03/21 03:16 PM Re: Mobile Deposits & Extended Holds cadym
RR Sarah Offline
Diamond Poster
RR Sarah
Joined: Mar 2004
Posts: 2,486
Up North
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.
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Sometimes you have to burn a few bridges to keep the crazies from following you.

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#2254795 - 06/03/21 03:22 PM Re: Mobile Deposits & Extended Holds cadym
cadym Offline
Member
Joined: Aug 2007
Posts: 51
Michigan
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

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#2254797 - 06/03/21 03:29 PM Re: Mobile Deposits & Extended Holds cadym
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,240
Illinois
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.
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#2254798 - 06/03/21 03:37 PM Re: Mobile Deposits & Extended Holds cadym
cadym Offline
Member
Joined: Aug 2007
Posts: 51
Michigan
Hello Brian,

This is very helpful!

Thank you

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#2254827 - 06/03/21 09:38 PM Re: Mobile Deposits & Extended Holds cadym
John Burnett Online
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John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
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.
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#2254838 - 06/04/21 12:23 PM Re: Mobile Deposits & Extended Holds cadym
cadym Offline
Member
Joined: Aug 2007
Posts: 51
Michigan
Thank you everyone for your input. This helps me tremendously!

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#2254884 - 06/04/21 07:06 PM Re: Mobile Deposits & Extended Holds cadym
madukes Offline
Diamond Poster
madukes
Joined: Jul 2009
Posts: 1,448
Flyers Country
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)

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#2254889 - 06/04/21 08:01 PM Re: Mobile Deposits & Extended Holds madukes
cadym Offline
Member
Joined: Aug 2007
Posts: 51
Michigan
We review most of ours as well for the same reasons. Still a couple have gotten thru.
Thanks for responding!

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#2255006 - 06/08/21 04:53 PM Re: Mobile Deposits & Extended Holds cadym
Susielou Offline
Gold Star
Joined: Aug 2005
Posts: 337
Midwest
What is your reason for placing the hold?

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