Remote Deposit Capture Check Images or ACH?

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1 Remote Deposit Capture Check Images or ACH? Prepared by: PAUL A. CARRUBBA Phone: (601)

2 Remote Deposit Capture Bank and Customer Agreement Items Cleared as Images RDC Agreement Items Cleared as ACH Entries Origination Agreement Bank Should Retain the Right of Clearing Method Both Require Scanners Both Require Connectivity Both Require Software or Processor Both Have Original Check Issues Both Have Similar Fraud Issues

3 Bank Office Conversion Requirements Contains a pre-printed serial number No Auxilary On-Us Field $25,000 or less Completed and signed by receiver

4 Bank Office Conversion Not Acceptable as BOC No magnetic ink Contains an auxiliary On-Us Field Greater than $25,000 Third party check No signature of receiver Credit card or HELOC checks Investment company checks Financial Institution check U.S. Treasury, Fed Reserve and Fed Home Loan State or Local drafts not payable through or at a Financial Institution Foreign checks

5 Bank Office Conversion Capture of MICR Information Must use reading device to capture MICR line May not key MICR line May key to correct errors

6 Bank Office Conversion - Warranties Additional ODFI Warranties Commercially Reasonable Procedures to Verify Identity of Originator or Third Party Sender

7 Bank Office Conversion - Warranties Documentation of Originators Company Name Address Telephone Number Contract Person TIN Description of the nature of the business

8 Bank Office Conversion - Warranties Provision of Originator Information to RDFI Ability to I.D. Originator within 2 days of request by RDFI Have ability for 2 years of settlement date

9 Bank Office Conversion Originator s Verification of Receiver s I.D. Originator Established Customer Service Phone Number Number must be displayed on notice

10 Bank Office Conversion Entry Information is Accurate Amount Routing Number Account Number Check Serial Number

11 Bank Office Conversion Copy of Source Document Reproducible, Legible, Image, Microfilm or copy of front of source document 2 years from settlement date Produce copy within 10 days of request Designation of copy on it s face

12 Bank Office Conversion Original may not be presented Warranty runs to any other liable party Secure Storage of Source Document and Information until destroyed Commercially reasonable method

13 Bank Office Conversion Liability for Breach to RDFI, ACH Operator & Association ODFI gives indemnification for breach ODFI liable to RDFI for causing Reg E breach

14 Bank Office Conversion Notice to Receiver Check may be converted to ACH or cleared as check Provide phone number of merchant Funds may be withdrawn from account same day Prominently Posted Copy Provided to Receiver

15 Bank Office Conversion Opt Out Reasonable procedures to opt out Applies only to one check Originator not obligated to process check Reg E and NACHA Rules Apply to BOC

16 Remote Deposit Capture - Images Check Requirements No restrictions on the type of check other than foreign items Options Third Party Substitute checks Their own checks Remotely created checks Amount limit

17 Remote Deposit Capture - Images Capture of Image Front and back Image Quality MICR information Magnetic OCR MICR repair Amount Scanner Requirements

18 Remote Deposit Capture - Images Original Checks Endorsement Process/Scanned stamp Storage and maintenance Destruction

19 Remote Deposit Capture - Images Image Exchange & Check 21 Issues Warranty Indemnification Accurate representation of front & back of check

20 Remote Deposit Capture - Images Availability Float Schedule Application of Reg CC Place of Deposit

21 Remote Deposit Capture - Images UCC Issues Does UCC Apply to Image? Warranties Holder Issue Security Interest

22 Remote Deposit Capture - Images Return Items Substitute Check Image MICR line ACH Deposit Original Rate of Return Cross Channel Returns

23 IMAGE vs BOS IMAGE BOC Check image Front & back Front Retention of image No requirement 2 years Production No requirement 10 days of request Destruction of original None required None required Image quality Check 21 Warranty Legible copy MICR Not required Required MICR line Required maybe keyed Required by not be keyed MICR correction Bank option Required MICR accuracy Check 21 required Required Auxilary On-Us No requirement May not have Signature requirement None (Check 21) Signature required In person presenters Not required Required Amount restriction None - bank option $25,000 or less Check type restriction U.S. checks only U. S. checks only

24 IMAGE vs BOS IMAGE BOC Option No third party N/A No credit card or HELOC N/A No investment company N/A No financial institution N/A No US Treasury, FED or FED Home N/A No State or Local Warrants Storage requirement None Security of check and info Endorsement None required None required Availability By agreement By agreement Original check May not be presented May not be presented Duplicate May not be presented May not be presented Depositary/ODFI WarrantyUCC Warranty/Contract t t Verification of originator i N/A Documentation of originator

25 IMAGE vs BOS IMAGE BOC N/A Provide originator notice to receiver N/A Receiver verification N/A Originator's phone number Notice Requirements None Check conversion notice Opt Out N/A Originator must offer opt out Check 21, UCC, Reg J, Reg E & NACHA Rules Application Law OP CR 3 Clearing & Settlement Direct, clearing agent ACH Operator Returned Items IRD, Image, ECP, ACH ACH Rt Return Deadline Midnight i deadline dli 2nd day after settlement t Unauthorized Deadline Midnight deadline 60 days after settlement

26 Remote Deposit Capture Check Images or ACH? Prepared by: PAUL A. CARRUBBA Phone: (601)

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