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hi my name is adam whitmer and i'm your host here compliancecohort.com this compliance clip is going to focus on regulation cc and the mobile deposit enforcement rule that just went into effect so effective july 1st of 2018 there are new rules under regulation cc now what happened here is the federal reserve took their liberties under regulation cc and they've amended the rules by telling us when or where the liability falls when a check is deposited twice in more than one financial institution so that's what's happening now this rule this rule change does not affect the holds the hold section of regulation cc it only affects the later subpart of regulation cc so under the prior rules let's take a look at those and see what they were and how this applied so the prior rules did not address mobile deposit capture and mobile deposit endorsements so what's mobile deposit capture well it's when a financial institution allows a customer to take a picture of a check and then send in that picture through mobile deposit now this also sort of relates to remote deposit capture but what we're talking about in this video is mobile deposit capture under the old rules regulation cc is so out of date that it frankly did not address mobile devices and mobile deposit capture so the rules were essentially silent so what that meant was that the liability or the indemnity for a check that was deposited at two different institutions would fall on the bank that was accepting the mobile deposit so what would happen is a customer would take a picture of a check deposit it mobility then take that physical check and then deposit it again at another financial institution who was liable well the financial institution that was taking the mobile deposit was the one liable because mobile deposits were not covered under regulation cc now the new rule has changed this basically the new rules say that a restrictive endorsement by the mobile deposit financial institution limits the liability so let's take a look at the preamble to the final rule to get a little bit better explanation of this what the preamble says is this it says the board referring to the federal reserve believes that the indemnity or liability places appropriate incentives on the party's best position to prevent multiple multiple deposits of the same item so who's best position well it's the financial institution that is taking the mobile deposit they're in the best position to prevent multiple deposits of that same check it goes on the preamble says the board has added a new exception to the indemnity in the final rule that would prevent an indemnified bank from making an identity claim if it accepted an original check containing a restrictive endorsement that is inconsistent with the means of deposits such as for mobile deposit only so they use the word dividing quite a bit in this language but...