Answer:
Most believe Remote Deposit of check images are subject to Reg CC mandates.
Who is most? That is definitely not the case.
https://www.ibat.org/legal-ease/2015/1/operations-mobile-banking-deposit...
http://www.nwcua.org/posts/cuna-mutual-releases-risk-alert-regarding-rem...
What is important is that you address funds availability in the RDC agreement.
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