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Fed Proposal: Availability of Funds and Collection of Checks
Tuesday, May 6, 2014 6:50 AM

On May 2, 2014, the Cornerstone Credit Union League submitted its comment letter on the Availability of Funds and Collection of Checks to the Board of Governors of the Federal Reserve System.

In writing the comment letter (which you can see in full here), Suzanne Yashewski, Cornerstone’s Regulatory Compliance Counsel, explained, "Cornerstone generally supports efforts to improve the check clearing process. However, we have concerns with the proposed changes relating to remote deposit capture (RDC). Our members feel the changes would increase risks for all financial institutions that offer RDC, and we ask the Board to consider appropriate, alternative approaches. In addition, we are concerned about the impact the proposal will have on small credit unions if all credit unions are required to use electronic returns. Finally, we request an extension of the effective date to at least one year after the final rule is issued, to provide adequate time for credit unions to implement any changes."

Other items of importance addressed include remote deposit capture, return requirements, same-day settlements, electronic checks and returns, electronically created items, and delayed effective.

Yashewski added that the proposed changes "will disproportionately impact smaller institutions, including some credit unions which currently rely on paper returns."

If you have any questions or would like more information on this proposal, please feel free to contact Suzanne Yashewski at syashewski@cornerstoneleague.coop or (512) 853-8516.