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Discussion Boards > Remote Deposit Capture Discussions > New Reg CC Amendments! Industry Discussion Starts Here. View modes: 
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John - 5/31/2017 3:13:53 PM
   
New Reg CC Amendments! Industry Discussion Starts Here.
The Federal Reserve Board on Wednesday announced final amendments to the check collection and return provisions in Regulation CC (Availability of Funds and Collection of Checks) and also requested further public comment on an additional proposed amendment to Regulation CC's liability provisions.

The final amendments update Regulation CC to reflect the evolution of the nation's check collection system from one that is largely paper-based to one that is virtually all electronic. The amendments create a framework for electronic check collection and return and create new warranties for electronic checks, which will result in a consistent warranty chain regardless of the check's form. As with existing rules for paper checks, the parties may, by mutual agreement, vary the effect of the amendments' provisions as they apply to electronic checks and electronic returned checks. The final amendments also modify the expeditious-return and notice of nonpayment requirements to create incentives for electronic presentment and return. The amendments become effective July 1, 2018.

In response to comments received, the Board is also requesting comment on proposed language amending Regulation CC's existing liability provisions to include a presumption that a substitute or electronic check was altered instead of forged in certain cases of doubt. Comments on the proposed amendments are requested within 60 days of publication in the Federal Register, which is expected shortly.

So... What's your take on the new changes? How will this impact the industry? 

Attachments:


FED Reg CC Docket R-1409
FED Reg CC Docket R-1564


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John - 5/31/2017 3:59:20 PM
   
RE:New Reg CC Amendments! Industry Discussion Starts Here.
New for RDC:

Finally, the Board proposed to add a new indemnity for remote deposit capture that would indemnify a depositary bank that received a deposit of an original paper check that was returned unpaid because the check was previously deposited using a remote deposit capture service and paid.  Commenters expressed concern that as proposed, the indemnity would deter financial institutions from offering remote deposit capture service, thereby inhibiting its growth.  
Many of these commenters believed that the indemnity should not apply to checks bearing a restrictive indorsement.   
The Board believes that the indemnity places appropriate incentives on the parties best positioned to prevent multiple deposits of the same item and has adopted the proposed indemnity.  Based on comments received, the Board has added an exception to the indemnity that would prevent an indemnified bank from making an indemnity claim if it accepted an original check containing a restrictive indorsement that is inconsistent with the means of deposit, such as “for mobile deposit only.”


-Page 13 of Docket R-1409

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John - 5/17/2018 2:06:42 PM
   
RE:New Reg CC Amendments! Industry Discussion Starts Here.
We recently hosted a webinar which covered what FIs need to know and do related to the new Reg CC. You can view the webinar or just download the pdf by clicking here

However, a very good question for FIs related to the restrictive endorsement;

Does anyone have any feedback on how others are addressing the following issue:
It’s July and the Reg CC changes are in place. The customer uses Mobile Deposit and we require them to put “For Mobile Deposit Only” on the back of the check. The deposit is rejected for one of the Risk Factors or being over their Daily or Monthly limit. The customer then goes to a bank to deposit or cash the check and is told no because of the endorsement.

How should this situation be handled?

Your feedback is appreciated.


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maybeida - 5/17/2018 3:50:26 PM
   
RE:New Reg CC Amendments! Industry Discussion Starts Here.
Our tellers will call the electronic services area that oversees mobile deposits,  Staff can access the site to verify if an item was accepted or not. 

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APLFCU - 5/17/2018 4:25:25 PM
   
RE:New Reg CC Amendments! Industry Discussion Starts Here.
Can the Electronic Services Area determine if it was mobile deposited at another FI and not yours?  It may not have been done at your FI.

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