Skip to content
BOL Conferences
Thread Options
#912083 - 02/28/08 03:29 PM Remote Deposit Capture & MSBs
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
What are your thoughts about offering this product to MSB customers ? There are risks involved of course.........need some help........please give opinions.

Thanks
_________________________
]

Return to Top
BSA/AML/CIP/OFAC Forum
#912162 - 02/28/08 04:37 PM Re: Remote Deposit Capture & MSBs CantBeShocked
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
As long as you have the proper internal controls in place for RDC, what difference is there really between in person deposits and RDC for an MSB??
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#912194 - 02/28/08 05:07 PM Re: Remote Deposit Capture & MSBs rlcarey
Milby Offline
Platinum Poster
Joined: Apr 2007
Posts: 953
Tejas
At a recent gathering of regulators, lawyers, and bankers in N. Texas, the general consensus was that this is not a good idea.

The difference between in-person and RDC deposits is that when they give me the physical check, I keep it. With RDC, they scan the check and keep it themselves. MSBs are already high risk customers...why offer them a high risk product as well?

I personally won't allow it. Just not worth the aggrevation.

Return to Top
#912202 - 02/28/08 05:11 PM Re: Remote Deposit Capture & MSBs Milby
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
I guess I was assuming that you meant image capture and not ACH conversion. I would agree that if you are contemplating ACH conversion, I would not do it.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#912349 - 02/28/08 07:00 PM Re: Remote Deposit Capture & MSBs rlcarey
markp Offline
Gold Star
Joined: Jan 2007
Posts: 382
New Jersey
Besides MSB's what other types of business do you regard as non acceptable industries for RDC.

Return to Top
#912354 - 02/28/08 07:08 PM Re: Remote Deposit Capture & MSBs markp
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
If you are talking about ACH conversions, any type of high risk customer in which you want to actually look at their deposits items for monitoring purposes.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#912520 - 02/28/08 09:51 PM Re: Remote Deposit Capture & MSBs rlcarey
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
Found out that legal asks that we do not sell the product to MSBs, Pawn Shops, consumers (business only), and a few other "higher risk" customers.
_________________________
]

Return to Top

Moderator:  Andy_Z