Nov 30, 2009—The Compliance Corner – Determining Suitability and Due Diligence Activities for RDC Customers

by Jackie Marshall, Director of IT Regulatory Compliance

One of the biggest challenges financial institutions face in complying with FFIEC Remote Deposit Capture (RDC) Guidance is dealing with a general lack of confidence that policies, procedures, and management strategies for proper suitability and due diligence management of RDC customers will meet examiners’ expectations.

This lack of confidence exists because, although the FFIEC guidance on risk management of RDC (finalized on 1/12/09) covers a number of specific areas, it is not prescriptive. However, financial institution personnel in charge of managing RDC can confidently draw upon previous experience to help implement a standard methodology for structuring suitability and determining appropriate ongoing due diligence of RDC customers.

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