Remote Capture and ID Theft Program

Back in February the FDIC conducted one of their quarterly conference calls-subject was the new Red Flag rules. One thing they mentioned that I'm struggling with is commercial accounts with remote transactions (remote capture). They stated that commercial accounts with these types of transactions would likley be a covered account.

Has anyone developed any red flags yet that would signal id theft related to these types of transactions?

Here are 2 things I could think of for red flags:

In the remote dep capture, there are several checks for the same account number on one day or over several days. In the remote dep capture, the usual amounts for customers range between $XX to $XX; however on this day one or more check amounts are much greater than the norm.

We utilize a velocity program in which we build deposit/dollar amount ranges over a 14 day cycle and the system would kick out a report if something was beyond that range. We would than call the company to confirm that the deposit is valid/authorized

While we included all types of deposit accounts, we did not include our actual Remote Deposit Capture product in our Red Flags Risk Assessment.

Did you?

Bueller, Bueller....

We also included all types of deposits accounts as "covered accounts", but not products within those accounts such as RDC.

We included it.