I'm auditing Reg CC compliance in a newly imaged environment. I don't see any BOFD responsibility for its own endorsement any longer. Does a BOFD need to place a physical or virtual Reg CC compliant endorsement on a check image it creates and transmits, or is it only up to a reconverting bank to place the BOFD's endorsement on the back of the printed image when creating a substitute check?

Thanks for the advice...