Remote Deposit Capture Compliance

Summary

This template is a Remote Deposit Capture Compliance guide for a compliance review of an insured depository institution (IDI)’s remote deposit capture (RDC) program. This template includes practical guidance and drafting notes. RDC is a treasury management service offered by some IDIs to their checking account customers. RDC allows the IDI’s customer to produce an electronic image of a check and transmit this image and other information through the U.S. payment system, allowing customers with a scanner or a mobile phone camera to deposit checks without having to make an in-person visit to an IDI location. Use this guide when performing a review of an IDI’s remote deposit capture policies, practices, and procedures to ensure the IDI’s compliance with applicable law and regulation. With some exceptions, any “No” responses to the questions posed by the guide should cause the board and senior management of the reviewed IDI to take action to remediate the issue. For a discussion of the laws and regulations applicable to RDC, see Law of Bank Deposits, Collections, & Credit Cards § 16.08 and the Federal Deposit Insurance Corporation’s primer on RDC in the context of bank examinations. For further guidance on RDC compliance, including sample policies, procedures and documentation, see Bank Policies: Guide to Regulatory Compliance § 5.26. Where an IDI uses a third-party vendor to provide RDC services, read this guide in conjunction with the Third-Party Vendor Management Checklist. You should review ACH Transactions Compliance and Training Guide § 11.10 for additional information on ACH transactions and compliance. For resources on payment processing regulations more generally, see Credit and Debit Card Regulatory Resource Kit.