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Managing Mobile RDC Risk

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24 June 2011
Bart Narter
Chase is the leader in mobile remote deposit capture (RDC), with more customers depositing more checks than anyone else in the market. I just received a notice from them that is essentially Chase practicing good risk management. Dear Chase Customer:You are receiving this message because you are enrolled in Chase QuickDepositSM. We want to provide you the following updates for this service.
  • You may deposit as much as $1,000 on any day and as much as $3,000 over any thirty (30) day period.
  • Federal Reserve Board Regulation CC (availability of funds) does not apply when you send us images of your electronic checks. Generally, you will be able to withdraw funds by the second business day after you make a deposit. However, we may delay access to your funds based on factors we determined in our sole discretion.
  • We may return or refuse to accept all or any part of a Chase QuickDeposit transaction at anytime. We are not liable if this would cause outstanding checks or other debits to your account not to be honored and returned.
Fundamentally they are limiting risk by limiting deposits and limiting availability. The first is pretty self-explanatory. The second takes into account that within two business days using image clearing, Chase is most likely to know that funds are good. This avoids the risk of intentional or unintentional duplicate presentment: a customer takes a picture of the check twice, perhaps at the same bank, perhaps at different banks. About 75% of all banks Celent surveyed have enterprise wide duplicate presentment monitoring, so if the check is presented twice at the same bank, it is likely to be discovered and submitted for clearing only once. If the check is deposited at two different banks, it will be submitted for clearing twice. The bank issuing the check will deny the second deposit attempt. Chase wants to make sure that it isn't the second bank having already making the funds available. Customers are likely to accept this with no trouble. Using mobile RDC allows the customer to deposit the check immediately upon receipt, rather than waiting until the next trip to the branch or ATM. The check could sit on the consumer's desk for days. In exchange for the convenience of mobile RDC, the customer may need to wait an additional day for availability. It's a fair trade off and a good move by Chase that I expect other banks will follow. How is your bank managing mobile RDC risk?

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