Post Reg CC: How have you adopted?

Banks and credit unions face many challenges when it comes to the minimization of risks and losses, but the level of acceptance varies for new solutions built to meet the regulatory demands in this area. On July 1, 2018, recommended protection to financial institutions (FIs) providing mobile remote deposit capture (mRDC) came in the form of a restrictive endorsement via the Reg CC changes.

With a restrictive endorsement, a written and intentional phrase of “For mobile deposit only at XYZ” can now reduce duplicate deposits and shift the payment liability; thus, prohibiting any further action or negotiability other than the language stated on the back of the check. See my previous blog for a quick recap.

In our industry, a restrictive endorsement is quite known, and based on recent results from’s monthly RDC Industry Research poll, nearly 70% of the FIs surveyed have welcomed a restrictive endorsement variant. Of those, about 50% adopted the full phrase of specifying the origination from mRDC and the intent to the bank of first deposit. The remaining 20% elected to use a phrase omitting “mobile” or the FI name, for a more general statement.


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