When setting up businesses for online banking, ACH, and remote deposit capture, does the bank maintain control over users of the business or do they set up an administrator for the business for them to maintain?
What is your opinion on the risks associated with allowing consumers (individuals or non-businesses) to use remote deposit capture services?
We have been offering remote deposit capture for nearly two years. The FFIEC guidance issued in January, 2009 says institutions should do a risk assessment first. We didn't. Is it too late?
How do you recommend that a Remote Deposit Capture customer secure its scanner? Is the scanner itself a security risk?
How long should a remote deposit capture customer keep the original checks?
How quickly do we need to give customers access to funds represented by remote deposit capture items. In other words, does Reg CC apply to consumer remote deposit capture items?
We are trying to assess the risk posed by offering remote deposit capture. Can you point us to any regulatory issuances that might be helpful? What is the associated risk with offering remote deposit capture in a US Territory…for instance the US Virgin Islands?