As we've blogged before, check writing has been steadily declining as electronic payments have grown. For example, the number of checks written in 2012 was 21 billion, down from 27.8 billion in 2009, according to the 2013 Federal Reserve Payments Study. We may be writing fewer checks than ever, but more than anything, we want the convenience of depositing our checks with mobile devices. A 2013 survey by ath Power Consulting found that mobile remote deposit capture (mRDC) is the "most sought-after mobile banking feature" among consumers. And financial institutions are answering this demand. According to 2014 surveys from Federal Reserve Banks (the Dallas Fed's, for example), about 48 percent of responding institutions are currently offering mobile capture and another 41 percent are planning to offer it within the next two years.
With mRDC in such demand, solutions providers and financial institutions should be investing in risk management strategies. But if check writing is a declining business, will mRDC risk management investments end up on the disabled list? Financial institutions must look at the potential losses and how they occur, evaluate the means to minimize these, and carefully weigh these factors against the dwindling check industry.
The mRDC channel faces two primary loss challenges: fraudulent items and duplicate check presentment. A fraudulent item might be an altered, forged, or counterfeit check; it can also be an intentional duplicate presentment. The other challenge occurs when a customer unintentionally presents a deposited item a second time. Research and anecdotal evidence suggest many duplicate presentments result from customer errors. These represent a growing customer education need. Financial institutions must find room in the allocated lineup and spending cap for fraud and duplicate detection enhancements.
Handling duplicate check presentments landed an all-star position on the agenda at most payments operation conferences this past year. Duplicate check presentments mean returns and adjustments, which in turn mean time and money for the financial institutions. When duplicate presentment involves more than one bank of first deposit, losses are often sustained from misunderstanding holder-in-due-course rights and return-versus-adjustment processes. Financial institutions often need to reconstruct what happened, analyze the facts, and possibly consult legal counsel.
But rather than handling these risks with expensive roster moves, considering the declining use of checks, financial institutions can meet the threat at the origin, through customer education and enforcement policies. Financial institutions that offer mRDC can make disclosed stipulations. For example, they can require that the original check be destroyed after confirmation, or that checks have a specific restrictive endorsement that includes "for mobile deposit only." Ultimately, if a consumer deposits a check twice, financial institutions can charge a fee or suspend service. In general, customers want to avoid fines, so they tend to play within the rules when fines are looming. If training customers is a home run in mitigation, then the grand slam is having detection systems that support the stipulations and rules put into place.
By Jessica J. Trundley, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed