How Are Other Institutions Preparing for the RDC and Regulation CC Updates?
Read the Survey Results
Our members have asked us for some best practices regarding NACHA's Remote Deposit (RDC) and Regulation CC updates going into effect July 1, 2018. We asked our readers to participate in a survey, so we can collectively see how our industry colleagues are preparing for the updates. A big thank you to all who completed the survey!
Survey Summary – The survey “Remote Deposit Capture and Regulation CC Updates” opened to the PAR/WACHA and Southern Financial Exchange newsletter readers on June 13, 2018. Forty-two responses were collected.
Two-thirds (66.67%) of respondents answered that they will be changing their endorsement requirements, though some have already modified their requirements and disclosure agreements. Most (67.5%) are monitoring mobile deposit endorsements that are less than $500 with an additional 22.5% of respondents monitoring endorsements between $500 and $2,500.
Respondents were split in regard to how they are educating their account holders on mobile deposit endorsements or how long they should retain the original item before destroying. Many are educating their account holders with a variety of methods including email, disclosures, website, app, agreements and even phone calls. Some participants noted that their organization has already started implementing modified or new disclosures and other education techniques.
If an account holder does not comply with the endorsement requirement, half of the respondents said they will call the account holder compared to those who will remove the service from the account holder (23.68%) or send a warning letter (15.79%).
The time is almost here! All eyes are on July 1, 2018 as the Federal Reserve's long-awaited amendments to Regulation CC are almost in effect. The upcoming changes modify the current check collection and return requirements to reflect the evolution of the nation’s check collection system from one that is predominantly paper based to one that is virtually all electronic.
This recorded session reviews the check payment system regulatory foundation with a discussion of Regulation CC. Part of the Code of Federal Regulations (CFR), Reg CC provisions were discussed in some detail. Scenarios were used to illustrate key warranties and how breach of warranty situations may be handled.
1.8 AAP & NCP Continued Education Credits