Remote Deposit Capture RSS Feed
Remote Deposit Capture Newsletter
Remote Deposit Capture Group on LinkedIn
Remote Deposit Capture Group onTwitter
The Green Sheet

Email Page 
Print Page 
 Add to LinkedIn Add to Twitter Add to Facebook Add to Reddit Add to StumbleUpon 
Add to Tumblr
Search discussion boards: 

Welcome to the Remote Deposit Capture Discussion Boards

Go back to Discussion Boards
Remote Deposit Capture Discussions Discuss the ins-&-outs of Remote Deposit Capture here. No vendor solicitations here please.
Discussion Boards > Remote Deposit Capture Discussions > Holding Original Checks View modes: 
User avatar
rdc1 - 4/26/2006 8:39:44 AM
Holding Original Checks
Originally Posted: Fri Jan 13, 2006 by "msharp"

I’m getting inconsistent information on how long companies need to hold original checks after making deposits remotely. I’ve always heard to hold on to original checks for up to 60 days after a deposit in case of unreadable images. I am now hearing a Payor Bank can return and request the original check if they find they consider the IRD quality unacceptable for up to 6 months after the deposit is made. Six months is a long time to hold on to original checks for high volume accounts.

Can checks really be returned for image quality this long after a deposit is made? This doesn't seem right, but am not sure where to look for the correct information. What seems to be the “normal” length of time original checks are held on to?

Reply by RDC1.....
Posted: Sat Jan 14, 2006 1:15 pm    Post subject: Retaining Checks

Thanks for your post.

There is no clear-cut timeframe in terms of a law, etc specifying how long you should hold onto your checks for. The retention period should probably depend upon a few factors for your specific scenario. I'll discuss them in a bit more detail below.

As for the 6-month time-period, there is no law which (to our knowledge) states that either. For more specific regulation information, please go to the following link: where you can find links to the Federal Reserve Reg page, and look closely at Reg CC and Reg E.

What we've generally heard is a 70-day retention period would be very prudent. Why 70 days? Most banks require account holders to report errors to their account within 30 days after they receive their statement. Add another 30 days to assume the check posts to the account on the 1st day of the cycle, then add 10 days as a buffer and you're at 70.

To make matters more confusing, RDC can clear items either as a "Check 21" item, or convert the item (as appropriate) to an ACH (ARC) - depending upon the capabilities of the RDC system you use. I believe Reg E requires checks converted to an ACH to be destroyed no later than 14 days later. So- you'll have to separate the converted items and destroy those within 14 days!

So far, we've heard everything from "since an IRD is a legal replacement of the original, you can destroy the originals almost immediately" to "Since a check may be returned due to fraud for up to a year, you should retain the originals for at least a year". Neither is 100% correct. Many banks are increasingly recommending a 60-day retention period on "Check-21" cleared items.

I hope this helps, and hopefully others will comment with their opinions.

Originally posted by Seac Shane....
Posted: Thu Feb 23, 2006 4:15 pm   

I would recommend that you speak to your financial institution regarding their requirements for check retention. Since you are making those deposits with them they are the ones who will ultimately establish the policy that they want their account holders to adhere to - at least until there is a real established guideline or law that makes the specifics that everyone will need to use.

Of course, I also believe that is why you should have the best image possible in order to produce an IRD. Just because the Fed wants a black and white image for transmission this does not prohibit an image in grayscale or color on an IRD. In fact X9.90 specifically states that "the image shall be representative of the original document (check or IRD) and shall accurately and legibly represent all of the information on the front of the doucment(check or IRD)"

That is why I always recommend either scanning in full color or grayscale and keeping those images so an accurate IRD can be produced if an image presentment is not acepted by the bank in the feds preferred black and white TIFF Group IV format.

Since an IRD is a legal representation and if you have IRD production capability then you should have no problem destroying the paper after capture provided you make sure your images are good and backed up!

Shane Kirk
Seac Banche USA, Inc.
Shane Kirk
Seac Banche USA, Inc.
(404) 460-5544

"Technology for Check Process Automation"

Originally Posted: Sun Mar 05, 2006 9:37 pm by cpdowdell...   

In the post-Check21 world an institution is enabled to image and shred the original check and produce a “substitute check” from the image upon request. However, the bank must warrant that the substitute check accurately represents the information from the front and back of the original check. Further, Check 21 does not address nor endorse imaging standards, outside of the nebulous “industry standards”, reducing the publication of a substitute check to an exercise in risk management.
As an FI accountholder - you should address your question(s) with the bank - and ensure that your staff follows procedures dictated by the FI.

Also, since Check 21 puts no destruction requirements on the truncating bank, a bank truncating the original paper check should evaluate its business considerations including but not limited to risk, cost, etc. in determining how long, if any, the original paper check should be retained. This may be construed as a "shared liability/cost" between you (the accountholder/depositor) and the FI.

In an image exchange where agreements are required, the agreement may provide for check retention requirements that a bank must fulfill. It is important to note that your FI may well have different requirements based upon different image exchange, i.e., clearing mechanisms/arrangements. Considerations for these agreements could also include various federal and state laws that may specify retention requirements.

User avatar
jimyritz - 11/14/2007 9:13:06 PM
Re: Holding Original Checks

Does anyone know if there have been any updates that have further defined the holding period or is it still up th each institution?


User avatar
Site admin
Site admin
ed.mclaughlin - 11/21/2007 3:13:52 AM
Re: Holding Original Checks

Not that I am aware of.

User avatar
Site admin
Site admin
ed.mclaughlin - 8/19/2008 9:05:28 PM
Re: Holding Original Checks
Does anyone know or think this will be addressed in the new FFIEC guidelines?

User avatar
Site admin
Site admin
Ed - 3/16/2010 3:56:17 PM
RE:Re: Holding Original Checks

The FFIEC guidance has been out for over a year now. How long are you recommending your customers hold their checks? Any suggestions on how to be sure they have destroyed the checks after the recommended length of time?

Latest posts

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 s...
Posted on 5/31/2017 3:59:20 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 provisio...
Posted on 5/31/2017 3:13:53 PM

RE:Cost Benefit Analysis- Breaking point of when a customer would qualify for an RDC.

While there are a myriad of variables which could go into both sides of this equation, we've at least made the benefits side a bit easier for you. Try the RDC Business Value Prop Calculator: RDC Biz Calculator 
Posted on 9/19/2016 1:36:39 PM

Cost Benefit Analysis- Breaking point of when a customer would qualify for an RDC.

Im looking to create a Cost Benefits Analysis per customer to determine when its best for a customer to be offered an RDC.  Anyone else has anything they might want to share to help me create this.  Thank you
Posted on 9/2/2016 4:17:10 PM

RE:Currently looking for a RDC vendor

CAR/LAR and coupon recognition software is an important part of this solution, as it can make or break it from the standpoint of automation and accuracy (Read rate and misread rates).  If you need any information to help you on this topic, please let me know. Joe Gregory
Posted on 8/18/2016 1:51:15 PM

RE:Currently looking for a RDC vendor

One resource is to use the RDC Solution Finder, a free service provided by  We can connect you with solution providers that meet your goals and objectives. You can also look at the Scanner Matrix for a comparison ...
Posted on 8/15/2016 5:23:33 PM

Currently looking for a RDC vendor

Hey All, I'm researching RDC vendors for the bank i work at. i have looked pretty intensely on this website and others for a vendor comparison.   I was curious if there was any good content regarding vendors for RDC on this website or any others. We are looking for a vendor that is...
Posted on 8/15/2016 4:04:45 PM

RE:OFAC & AML Requirements

What is not clear is the clarification of what the examiners want. No clearinghouse or the FED runs payees through OFAC what technologies are available that is 100% reliable to prevent  a high speed environment like checks to be compliant? I welcome feedback
Posted on 5/31/2016 8:35:45 PM

OFAC & AML Requirements

I recently received the following inquiry about OFAC & AML Compliance regarding RDC. What are your thoughts??... I know that scanners should not be taken out of the country and FI’s should know their customers and that they are not doing any foreign items through RDC. But examiners are...
Posted on 5/23/2016 1:43:47 PM

Can mobile deposit really replace commercial RDC scanners?

This a paid advertisement posted by on the behalf of Mitek. Can mobile deposit really replace commercial RDC scanners? We think so. Most of them, anyway. Mitek's new Mobile Multi-check Capture optimizes the user experience allowing lower...
Posted on 3/25/2016 9:26:49 AM