According to a Federal Deposit Insurance Corporation survey of depository institutions, approximately 38 percent of institutions offer some form of remote deposit capture (RDC) service. RDC enables a customer to deposit checks and other items electronically through the internet or the customer’s mobile phone. The service was first authorized in 2004 when Congress passed the “Check Clearing for the 21st Century Act.” RDC may help an institution expand its geographic reach by offering deposit services to customers who are not located nearby one of the institution’s branches or other offices. However, the federal banking agencies are mindful of the risks involved with RDC services, including the need to protect customers’ nonpublic personal information, and have stressed sound risk management practices tailored to RDC.
The federal banking agencies recommend that institutions address RDC services in their existing risk assessments, implement physical and logical access controls over RDC data and services, impose risk-based guidelines to determine which customers should be eligible for use of the service, offer RDC training for customers, and consider applicable laws and regulations such as the Check Clearing for the 21st Century Act, Federal Reserve Regulation CC and Regulation J, applicable state laws and regulations, and other guidance. Risk management for RDC should also address the use of third-party vendors and service providers. According to the survey, 68 percent of institutions that offer RDC rely on either a third-party program or third-party software or hardware owned by the third-party. For this reason, institutions should pay close attention to third-party risk in providing RDC services.