The Missouri Credit Union Association (MCUA) submitted a comment letter on May 2, 2014, on the Federal Reserve Board’s (Board) Regulation CC proposed rule. MCUA generally supports efforts to improve the check clearing process and to account for the shift toward fully electronic checks but has concerns with proposed changes relating to remote deposit capture (RDC).
In response to concerns raised by credit unions that the changes would likely increase risks for all financial institutions that offer RDC, MCUA asked the Board to consider appropriate, alternative approaches. In addition, MCUA urged the Board to minimize the impact to smaller institutions from the proposed changes, including the proposed return requirements that would encourage all institutions to use electronic returns. Further, MCUA asked for a delayed effective date of at least one year to provide adequate time for credit unions and others to implement any changes.