Regulation CC has been badly out-of-date for over eight years. Yes, it was February 2010 when the Federal Reserve finished consolidating its check processing regions and the “nonlocal check” ceased to exist. Almost all banks have shifted to electronic collection of the checks they process, and to the acceptance of electronic return checks. Yet the regulation hasn’t kept pace with any of these changes!
Is your bank one of the few hold-outs that still gets paper return checks? The Federal Reserve’s May 2017 amendments to Reg CC may be the incentive you need to take the all-electronic plunge. Its changes to subparts C (Collection of Checks) and D (Substitute Checks) stack the deck against banks that hang on to paper cash letters, and tighten up a bit on deadlines that banks need to meet. The rule also makes some related changes to the definitions in section 229.2. Left untouched (for now) is subpart B, where most of the outdated “local/nonlocal” language and outdated disclosure requirements remain.
The Fed gave institutions about a year – until July 1, 2018 – to comply with the amended regulation. By then, your institution and any third-party providers involved will have to complete necessary technology, policy and training changes to complete your implementation of the new requirements. Time is getting short.
In his two-hour presentation, BOL Guru John Burnett won’t waste time with history. The focus will be on the future, as he discusses these topics—
- Electronic check clearing statistics
- Electronic check returns statistics
- Elimination of the "forward collection" test
- The notice of nonpayment - Timing and trigger
- Incentives for accepting electronic returns
- Liability for late returns
- Same-day settlement rule
- Electronic checks and returned checks
- Warranties and the new indemnities
- Electronically created items
- Unauthorized electronically created items
- Remote deposit capture indemnity
- What remains to be changed, and by whom
- And more
WHO SHOULD ATTEND:
Operations management and key members of auditing, compliance, deposit operations and IT departments