Remote Deposit Capture Guidance

On January 19, 2009, FIL – 4- 2009 – Risk Management of Remote Deposit Capture was published. The guidance is pretty much what we expected, with a few twists. The theme of the guidance compliments the guidance of late—Risk Management. The guidance states that a financial institution offering Remote Deposit Capture (RDC) should have in place sound risk management and mitigation systems and require adequate risk management at customer locations including, but not limited to, controls over nonpublic personal information. Further, financial institutions whose RDC systems use the Internet as a communication channel should use effective methods to authenticate the identity of customers using those services. Single-factor authentication methods may not provide sufficient protection. The guidance clearly states that RDC should be viewed as a new delivery system, not simply a new service.

RLR has prepared an overall summary of the guidance. In addition, we have prepared a presentation that will help financial institutions better understand the guidance.

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