Can anyone tell me if regulatory approval is required for a financial institution to implement remote deposit capture?

I'm not sure what exactly you mean by this. Are you talking about a traveling branch or courier service? Can you clarify for me? Thanks, Sheryl

Sorry, I'm talking a scenario where commercial customers have equipment in their place of business that enables them to make a deposit(excluding cash of course) by transmitting images of the deposit ticket and the checks they want to deposit thereby saving them a trip to the bank!

No, regulatory approval is not required

I'm a board member of a bank in IL that just implemented Remote Deposit in January. We had an FDIC exam at the end of January and very little was even asked about the program.

Thank you!

If you want to advertise, contact Tobi@bankersonline.com .

Make sure you have some good language in your agreement with the commercial customer who wants to begin doing this. Under Check 21, the first bank who accepts an IRD created by a non-financial institution accepts ALL the liability that goes along with an IRD. You can't reassign this liability to the customer. The best you can do is try to get them to agree to cover any losses that you, as the responsible institution, will have to incur in the event of problems with the IRD.

Thank you - any other suggestions or things we should be thinking about?? Obviously, not rushing into this. But want to be prepared when management says they're ready and want to implement it yesterday!

I saw your Feb. post re Remote Deposit Capture. I'm a lawyer in St. Louis and have a client who is interested in participating in a RDC program but they want to see an example of the contract. Could you provide me with any leads re how I might obtain a generic copy of a standard RDC contract? Please email me directly (shall@lewisrice.com). Thanks.

I am also interested in obtaining a source for a contract for remote deposit capture.

i would also like to see a contract if possible. please email to hurowitz@aol.com

I would also like to see an agreement sample if you don't mind sharing. Please e-mail to monarobertson@aol.com. I would greatly appreciate this info.

Thanks

I can't help you out with a contract but here is a message board for www.remotedepositcapture.com where you might be able to post this same question and get a better reply.

Tom Houston has 6 posts, in a row, of self promotion. (Five to be deleted.) I suggest he contact tobi@bankersonline.com to pay for advertising and stop the self promotion here in the threads.

See www.thouston.com for in-bank, one-day Workshop that includes all of the documents you need.

Tom Houston
832-236-4641

www.thouston.com

All documents you need.

Tom Houston

I am speaking at the CBAI Technlogy Meeting in April and will address the issue, but we also have all of the documents (agreement, risk, etc)


Tom Houston
832-236-4641

Congratulations Tom,
You've made a dandy impression. If we are in dire need of spam we will call you.

What concerns are there for businesses using remote deposit capture and leaving the images previously transmitted unsecured on their network? We are concerned that since our system would be used to scan and transmit the images that we might be liable? Has anyone else reviewed this risk?

So, back to the original intent of this post...

As much as I hate to show my ignorance, what law/regulation would cover RDC? Does this fall under Check 21? Reg CC? Reg E?

Aside from the shameless self-promotion and the glut of advertisements I find using search engines, have any of the regulatory agencies issued any guidelines?