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Remote Deposit-Reg E as Electronic Funds Transfer?

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Is Remote Deposit covered by Reg E as an electronic funds transfer? Is this clarified anywhere?

It is if the remote deposit capture is done by capturing the MICR data on a check, adding the dollar amount and submitting an ACH entry against a consumer's deposit account. That would include, for example, POP, BOC and ARC entries.

It is not if an image of the check is captured and forwarded for electronic presentment in that form.

First published on 4/16/12

First published on 04/16/2012

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Filed under compliance as: 

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