Compliance Question of the Week

We are starting to offer Remote Deposit Capture to our members. Is there some sort of Reg CC deposit availability disclosure we need to provide?

Regulation CC does have specific requirements for when credit unions need to provide members with notice that the funds of the deposit may not be immediately available.  But Regulation CC does not currently cover Remote Deposit Capture.

This leaves the disclosure agreement that is provided when a member signs up for the service as the document that best describes funds availability associated with Remote Deposit Capture.

Related Links

12 CFR 229.18
FFIEC guidance Remote Deposit Capture
OCC Interpretive Letter #1036

 

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Compliance.