Remote Deposit Capture : Compliance Challenges in the News
ABA Banking Journal recently ran an article written by Dan Fisher titled “RDC Compliance Remains Thin.” Dan discusses the FFIEC guidelines for Remote Deposit Capture that were released January 14, 2009. He notes that the guidance “is much more far reaching [than the industry expected] and carries with it a significant impact on the management of technology.”
Our last Control Tv episode featured Remote Deposit Capture and Susan Orr’s RDC ActionPack on our Control platform. RDC challenges brought up in Dan’s article and covered in the Susan Orr RDC ActionPack include:
- Thorough due diligence, identifying associated risks in advance of implementing any new RDC technology or product.
- Inadequate MIS reporting and lack of monitoring were among the greatest challenges in RDC exam findings with regard to the FFIEC guidance and compliance. “The translation is simple one: looking at a threshold-limit violation 30 days after the fact is not an effective risk management, monitoring, and mitigation program”, wrote Dan.
- Identifying, assessing, managing, monitoring, and mitigating RDC risks up front. Dan reflected, “The theory of the guidance is to look ahead to see a potential problem rather than look back and realize you have one.”
As Andy Greenawalt says, “The controls needed aren’t that complex, but are too infrequently deployed.” At Continuity we’re here, with the ActionPack Alliance to help you take the headaches out of compliance.
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