Answer:
by Randy Carey:
All checks are subject to Reg. CC if they are deposited into a transaction account.
Answer:
by Jim Bedsole:
Randy, I would clarify a point that there is evolving guidance on whether checks deposited via mobile deposit or mobile remote deposit capture are subject to Reg CC availability rules. There have been good arguments made that as currently stated, Reg CC does not apply to deposits of checks through mobile deposit. In their proposed revisions to Reg CC, this will be addressed once the rules are made final. This doesn't impact the answer to the original question as the fact that the check originated through a bill pay application has no bearing on whether it would be subject to Reg CC.
Answer:
by Randy Carey:
I agree and have been one of the proponents on the subject that Reg. CC does not apply to the deposit of items that are purely images of checks.
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