Answer by Jim Bedsole:Probably about all you're going to get from here on this question is an assertion that such risks do exist and you'll need to conduct your own risk assessment to determine the likelihood and impact of those risks, and whether they can be sufficiently mitigated to an acceptable level given the expected level of return with the product offering. Risks would include such things as customer re-presentation of items already submitted remotely, whether intentional or unintentional, and failure of customer to adequately protect computer systems used to access remote deposit services. The FFIEC put out some information that may help you with the risk assessment process available here.You can also find some trade information that may be useful to the process, and sometimes has some contrary views to the regulatory risk perceptions here. As a specific disclaimer for this post since it solicited "opinion", let me be specific and state that the opinions I have offered here are my personal opinions and do not necessarily reflect the views of my employer or Bankers Online.
Answer by John Burnett:If you are familiar with some of the risks inherent in offering RCD to business customers, whether you do it yourself or some third party has signed them up, when you take RDC to the consumer, any hope is gone for internal controls (other than basic honesty) to prevent double-presentments. On the other hand, the volume of checks you can expect from a consumer is a lot lower than from a business, and that's a mitigating factor.
First published on BankersOnline.com 11/22/10