Alert January 27, 2009

FFIEC Issues Guidance on Remote Deposit Capture Programs

The FFIEC issued risk management guidance on remote deposit capture programs. The guidance concludes that banks offering remote deposit capture programs should (1) have sound risk management and mitigation systems in place and require adequate risk management at their customers’ locations; (2) identify the types and levels of related risk exposure prior to implementing the program and periodically thereafter; (3) develop comprehensive contracts that clearly identify the roles, responsibilities, and liabilities of all parties in the process to minimize exposure to legal and compliance risks; (4) implement appropriate technology and process controls at both the bank and customer locations to address operational risk; (5) implement risk measurement and monitoring systems, and require customers to do the same; and (6) consider insurance coverage. Click here for the guidance.