Mar 5, 2010—The Compliance Corner – Managing RDC Risk through Exception and Trend Analysis

by Jackie Marshall, Director of IT Regulatory Compliance

An excerpt from the Q1/2010 issue of the Gladiator newsletter, The Shield –

A provision of the January 2009 FFIEC guidance on risk management of Remote Deposit Capture (RDC) includes a focus on implementing high standards for qualifying merchants and due diligence in assessing merchant contract compliance on an annual basis. These standards also support KYC and BSA/AML objectives. A strong methodology for merchant qualification is the cornerstone of a financial institution’s (FI’s) successful RDC program. However, another related provision of the guidance that builds on this foundation is not as well understood – that is the expectation for ongoing analysis of merchant deposit activity.

Recent examiner feedback indicates that many FIs need to do a better job in capitalizing upon the tools built into their RDC application software to implement a more consistent approach for analyzing deposits. (continued)

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