Effective July 1, 2018, the Federal Reserve Board made amendments to Regulation CC providing clarification on the requirements of mobile deposit endorsements and who has liability in the event of a duplicated check deposit.  This leaves financial institutions with a decision to make on whether or not to change the endorsement requirements for any mobile check deposits.  Talking to your compliance officer will help you make the best decision on these requirements, while Bank-A-Count Corporation can help make any changes a smooth transition with our variety of endorsement stamp products.

Before these Regulation CC changes, liability for a check that was deposited twice (once by mobile deposit at Bank A and once by paper check at Bank B) would fall upon Bank A, leaving them to try to get the money back from the depositing customer.

With the new regulations in place, financial institutions accepting mobile deposits now may have protection if they use a “restrictive endorsement.”  In other words, if the financial institution accepting a mobile deposit requires an endorsement that prevents duplicate deposits, then they are less likely to have an indemnity claim filed against them by a different financial institution that accepted the duplicate paper check.  Although these “restrictive endorsements” can be hand written, Bank-A-Count’s high-quality, low cost endorsement stamps can make the process quicker, easier, and more efficient by ensuring a standardized and consistent endorsement message.

So what exactly constitutes a “restrictive endorsement?”  Although Regulation CC does not give exact language on what should be used, certain portions of the official regulation use the examples of “for mobile deposit only” and “for mobile deposit at Depository Bank A only.”

So what can you do to protect yourself from any potential liability issues?  Stay informed and be prepared!  Bank-A-Count Corporation can help with our variety of endorsement stamp options, geared to fit any needs you might have.  Talk to your compliance officer today to create the language you would like for your stamp, and we will customize it to your exact specifications.

To learn more about these stamps, visit www.bank-a-count.com/productinfo/preinked-stamps

For more information about Regulation CC: www.federalreserve.gov/newsevents/pressreleases/bcreg20170531a.htm