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...four broad areas: implications based the form of remote capture the bank selects; data protection issues; disclosure issues; and the impact on availability and potential issues with overdrafts and overdraft protection.
A general overview, to raise awareness of these issues, was presented in March at an ABA Banking Journal-sponsored briefing by Nessa E. Feddis, senior federal counsel in ABA's Government Relations Group.
How RDC is offered matters
Remote deposit capture comes in two "flavors," each with different compliance implications: 1. The check can be captured and processed as an imaged check under Check 21 rules. 2. Once scanned, a check can be converted into an automated clearinghouse transaction.
A check that is converted to an image and processed under Check 21 is subject to Regulation CC and other applicable checking laws and regulations,...
NOTE: All illustrations and photos
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