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A new blog from NAFCU Senior Regulatory Compliance Counsel Stephanie Lyon provides credit unions with an overview of changes to Regulation CC as the Federal Reserve Board's final rule amending subparts A, C, and D as well as the official staff commentary went into effect Sunday.

The final rule modifies the current check collection and return requirements to reflect today’s virtually all-electronic check collection and return environment. It encourages all depositary banks to receive, and paying banks to send, returned checks electronically.

Lyon writes that the effective date primarily means "credit unions offering remote deposit capture (RDC) technology should have finalized any changes made to their RDC agreements, policies and procedures to ensure the correct restrictive indorsements are placed on these remotely deposited checks."

She notes that the correct restrictive phrase to use for a remotely deposited check is regulated by both federal and state laws, and explains what credit unions need to know for each of those requirements.

NAFCU also has available a redline of the changes to Regulation CC.