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#208980 - 07/08/04 09:44 PM Implementation date
Anonymous
Unregistered

Is there any expectation that the implementation date will be delayed?

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Deposits and Payments
#208981 - 07/09/04 02:12 AM Re: Implementation date
Bill Saffici Offline
100 Club
Bill Saffici
Joined: Dec 2003
Posts: 155
Philadelphia
I am quite certain there will be no delay in the implementation date. Remember there is not a significant amount of work that has to be done to prepare for the implementation date. The following will take you to a document on the ECCHO website and identifies the minimum requirments for the implementation of Check 21.
Check 21 Minimum Requirments

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#208982 - 07/09/04 08:24 PM Re: Implementation date
Anonymous
Unregistered

I completely agree with Bill. Since the law doesn't require any bank to create images, or to accept them, no one is being "forced" to make sweeping operational or technological changes by this new law. There's no reason for a setback of the effective date.

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#208983 - 07/09/04 09:48 PM Re: Implementation date
GenerousLife Offline
Diamond Poster
Joined: Feb 2002
Posts: 1,466
USA
Second question: Will the Federal Reserve be ready, operationally speaking?
_________________________
"No problem can withstand the assault of sustained thinking." ~ Voltaire
"Sustained thinking gives me a headache." ~Me

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#208984 - 07/10/04 02:07 AM Re: Implementation date
Bill Saffici Offline
100 Club
Bill Saffici
Joined: Dec 2003
Posts: 155
Philadelphia
Be ready for what? Yes, the FRB is marketing new services related to Check 21. However, there is a requirement that any bank/service provider who wishes to submit an image cash letter must complete a certification process. This certification is to ensure data communications is working and secure and the file meets the X9.37 DSTU format with the FRB Companion Document. Additionally, the depositary bank must understand the changes that will be reflected in the revision to Operating Circular #3, which is the agreement under which image exchange with the FRB will be governed. The certification has been stated to possibly take as long as 60 days and it is not known how many the FRB can handle simultaneously. As I previoulsy stated and Mary Beth acknowledged, there is no specific requirement come Oct 28 to begin exchanging electronically. In fact, after the FRB announces their pricing/RT list on Aug 28, banks who wish to participate in sending an image cash letter to the FRB must carefully match the mix of their items against the RT list the FRB will provide. This is to determine the cost of clearing in an image cash letter mode since it is possible that many items will have to be converted to substitute checks, therefore, potentially having a higher clearing cost. Creating IRDs or having a deposit converted to IRDs should be solely based on business case criteria not just a new way to process.

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