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#2281225 - 02/16/23 08:08 PM RDC Redeposit - Reg CC Or Policy Issue
Calaban Offline
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Joined: Feb 2023
Posts: 3
I appreciate if I could get clarification!

A remotely created check was deposited and the item was returned for NSF. The item was re-deposited ( has the Substitute Check information) and a redeposit exception hold was placed. RDC Master Agreement states that funds for all accepted checks will be available in accordance with our fund’s availability schedule, governed by Federal Reserve Board Regulation CC. Deposits made under remote deposit capture are not governed under Reg. CC. But if there is an issue with the exception hold placed on the redeposited check, for example, exception hold was not removed when the item was charged back OR the Notice of Hold is missing deposit hold information, would these issues be considered policy or reg. issue?

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#2281239 - 02/17/23 12:02 PM Re: RDC Redeposit - Reg CC Or Policy Issue Calaban
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,368
Galveston, TX
Reg CC does not apply to RDC, so whatever you do, it cannot be a violation of that regulation. Your availability policy for RDC should be spelled out in your agreement with the customer. If you did not follow that, then you have a breach of contract.
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#2281286 - 02/18/23 01:32 AM Re: RDC Redeposit - Reg CC Or Policy Issue Calaban
Calaban Offline
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Joined: Feb 2023
Posts: 3
Thank you.

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#2281421 - 02/22/23 07:51 PM Re: RDC Redeposit - Reg CC Or Policy Issue Calaban
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
In your OP, you opened with "A remotely created check." Is that accurate (it may be irrelevant).
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#2281438 - 02/23/23 02:12 AM Re: RDC Redeposit - Reg CC Or Policy Issue Calaban
Calaban Offline
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Joined: Feb 2023
Posts: 3
Sorry, it is "Electronically created item."

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#2281626 - 02/27/23 08:20 PM Re: RDC Redeposit - Reg CC Or Policy Issue Calaban
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Okay, "Electronically created item" and "Remote Deposit Captured check" aren't necessarily one and the same.
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