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Third Party RDC Services

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I'm the compliance officer at a small community bank. We do not offer remote deposit capture, but from what I understand, some of our bank's commercial deposit customers have gone out on their own initiative and obtained RDC services from various third parties. Our customers are then using this platform to make deposits to their accounts at our bank. This would seem to involve risks to our bank, but I'm getting a lot of push-back from the sales side, that because our bank had nothing to do with the customer's decision to enroll in or obtain these RDC services, the bank has absolutely no risk. I'm not as convinced about that. Any help and or guidance appreciated.

The risk to the bank with the third party involvement could be considerably greater, particularly when the third party is outside your influence. There remains the potential for a check to be processed/deposited more than once and other forms of fraud (or, more charitably, customer error). You also don't have access to images of the deposited items to review for suspicious activity or for inter-account transfers that you might otherwise have blocked as part of an RDC agreement, as you would if you or your third party contractor were supplying the service.

First published on 9/13/10

First published on 09/13/2010

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