RDC used for personal acct

Posted By: peoples

RDC used for personal acct - 08/08/14 06:46 PM

We have a RDC business customer that want to start making deposits to his personal acct via RDC. We told the customer RDC was for business purposes only and he indicated that his prior bank allowed personal checks to be deposited. Needless to say, if we allow RDC to be used for personal accounts we will modify our RDC agreement.

If we choose to allow the customer to use RDC for personal accts what issues regulatory or otherwise should I be aware of? Also, would their be any compliance disclosures required for the consumer deposits made via RDC?
Posted By: rlcarey

Re: RDC used for personal acct - 08/08/14 06:53 PM

he indicated that his prior bank allowed personal checks to be deposited.

Maybe that is why it is his prior bank.

You make the rules not him. If you don't offer a consumer RDC product with the proper contracts, vetting and procedures in place, you don't offer it. This is not a product to offer on a one-off basis.
Posted By: John Burnett

Re: RDC used for personal acct - 08/11/14 03:08 PM

I want to second Randy Carey's response, and offer this additional suggestion: Typically, RDC installations offer a connection to only one deposit account: in your case, it would be the business account. Depositing checks payable to the individual creates potential for endorsement problems, the potential for the individual to ask for on-line access for transferring funds out of the business and into the personal account, and so on.

If you offer RDC to personal accounts (typically mobile RDC or mRDC is used), he can apply for that access for his personal checks.