RDC and Regulation CC Holds

In the past, there are threads that suggest that Reg CC considers items submitted through remote/mobile deposit to be neither electronic items nor checks (and as such are not subject to Reg CC holds). And that many in the industry believe that RDC deposited items should follow the rules for items not deposited in person. A concerned would be about straying too far away from Reg CC for these items for UDDAP reasons. Is this practice still current?

RDC deposits are giverned by uour RDC agreement since Reg CC does not include an image in its definition of a check. You can choose to inforporate RDC into your funds availability policy and follow the same availability schedule, but there is no regulatory mandate that you do so.

One of the reasons I suggest mirroring your Reg CC availability schedule is that the Fed and Bureau may some day stun us all and bring subpart B of Regulation CC into something current, with updated disclosure formats, no mention of nonlocal checks, and, yes deposits of checks captured in image format, remotely. When that happens, if your schedule for RDC/mRDC image deposits varies from your schedule for paper checks, you'll have notice requirements.

On the other hand, maybe everyone will finally abandon the use of checks, and we can all put a permanent exception hold on Reg CC.

I don't have much faith in either outcome.