9/9/2008 1:26:20 AM
RDC Risk Management / FFIEC Guidance
There have been a number of individuals (including myself) who (mistakenly) understood that the upcoming FFIEC Guidance will not apply to Consumer Capture.... That is incorrect.
I have just confirmed, via a direct conversation with the appropriate regulators:
The FFIEC guidance on RDC will apply to all forms of Remote Deposit Capture, including Consumer Capture.
The upcoming FFIEC Guidance is primarily based upon the current state and experience of the industry (pre-september 2008), and as such is built upon the experiences of the industry to date, which is primarily a relationship between a corporaion or business and their Financial Institution. Nevertheless, risk management practices should be uniquely tailored to each FI and their RDC customer.
Currently, it is estimated the guidance will be issued in October 2008.
More on this subject, including RDC Risk Management Best Practices, will be posted soon.