On January 14, the Office of Thrift Supervision, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency and the Federal Financial Institutions Examination Council State Liaison Committee (collectively, the Banking Agencies) released guidance for examiners, financial institutions and technology service providers to identify risks, evaluate controls and assess risk management practices related to remote deposit capture (RDC) systems.
RDC is used to enable financial institution customers to make deposits from their homes or businesses instead of taking such depositsdirectly to a financial institution. In this process, digital information is captured at the home or business of the customer and transmitted to the financial institution or such institution’s service provider for clearing and settlement. RDC may also be used by financial institutions in their branches. While introducing additional risks to financial institutions, RDC benefits financial institutions because it “decreases processing costs, supports new and existing banking products, and improves customers’ access to their deposits.”
As identified by the Banking Agencies, the essential components of RDC risk management include identifying, assessing and mitigating risk, as well as measuring and monitoring residual risk exposure. The guidance further states that management should ensure that RDC is compatible with the institution’s business strategies before implementing the program and understand the return on investment and management’s ability to manage the associated risks of such a program. Interagency RDC examination procedures will be forthcoming in 2009.