Mobile Deposit Review™

Are you ready for Mobile Remote Deposit Capture?mobile-deposit

If you already offer RDC for businesses, some of this should be familiar, but where we find financial institutions get hung up is on the fact that there are some differences between consumer and corporate capture. The biggest is around determining who of your consumer customers you will allow to use the service, what are the parameters and how do you automate that decisioning. Additionally, what should the limits be, should you create tiers, and if so, what do they look like. The FFIEC is going to require the following of an FI that deploys mobile deposit:
  • Policy outlining service eligibility, limits and other restrictions
  • Risk mitigation systems and operational procedures
  • Oversight and on going monitoring (reports)
  • Guidelines for internal audit
  • Update Internet Banking Risk Assessment to incorporate Mobile RDC (FFIEC Supplement to Authentication in an Internet Banking Environment, June 28, 2011)
  • Product readiness – Risk, Security and Compliance
    • Requirements for product implementation and configuration
    • Authentication techniques that meet the regulators definition of “high risk transactions”
    • Solution fit within the enterprise risk management for deposit processing
    • New or changed operational procedures
  • Customer agreements, end user license agreements and disclosures
  • Customer facing documentation is consistent with product features, bank policies for mobile RDC, and meet FFIEC guidance for Customer Awareness and Education
MSP consultants have helped numerous FI’s and their vendors manage these issues, fleshing out requirements for eligibility and limits the business and risk teams can agree upon.

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