We are in a "Hold All" environment for Reg CC purposes. In planning for remote deposit capture I am trying to determine how we will separate out the official checks from the other checks that are subject to local/foreign holds. Can a remote deposit capture customer be viewed the same as a non-proprietaty ATM? (Not that I am planning on holding checks that long, I just want to know if I need to make special arrangements for official checks or if I could just treat them the same as either local/foreign checks.)

You might want to check, but I thought that I was told that Remote Deposits were not subject to Reg CC. Honestly, I don't remember where I heard that.

I think Reg CC would still apply, just that the notice isn't required to be given to the customer at the time of the deposit in order to avoid liability for fee incurred due to the deposits not being made in person by the account owner?