Regulation CC – FINALLY a Final Rule!

Recorded on August 8, 2017   |   With John Burnett

Regulation CC – FINALLY a Final Rule!

With John Burnett
  • 1 Video
  • 2.0 hrs
Course description

ICB Credit: 2.5 CRCM

With the enactment of the Check 21 Act and the introduction of the Substitute Check, U.S. banks got the legal underpinning they needed to start collecting checks electronically instead of shipping them across the country. And with that, Regulation CC began to get more outdated each year until 2010, when the Federal Reserve finished combining all its check processing regions into one, and overnight, nonlocal checks became part of history, and huge portions of the regulation became irrelevant.
Since then, the Federal Reserve has floated two proposals - in 2011 and 2014 - to bring the regulation up to date by culling out the outdated language required under the local/nonlocal check paradigm, reflect the new electronic collection and return of checks.

Part of that effort has now been completed. In May 2017 the Federal Reserve released a final rule making significant changes in two subparts of the regulation - subpart C (Collection of Checks) and subpart D (Substitute Checks). The rule also made some related changes to the definitions in section 229.2. Left untouched (for now) is subpart B, where most of the outdated "local/nonlocal" language is found.

The Fed has given institutions about a year - until July 1, 2018 - to comply with the amended regulation. In that time, your institution and any third-party providers involved will have to make necessary technology, policy and consumer disclosure changes to complete your implementation of the new requirements. It's not too soon to start studying the new rule.

In his two-hour presentation, BOL Guru John Burnett won't waste time with history. The focus will be on the future, as he discusses these topics-

  • Electronic check clearing statistics
  • Elimination of the "forward collection" test
  • The notice of nonpayment - Timing and trigger
  • Incentives for accepting electronic returns
  • Liability for late returns
  • Same-day settlement rule
  • Electronic checks and returned checks
  • Warranties and indemnities
  • Electronically created items
  • Unauthorized electronically created items
  • Remote deposit capture indemnity
  • What remains to be changed, and by whom
  • And more ….


Operations management and key members of auditing, compliance, deposit operations and IT departments

Course Curriculum

Regulation CC – FINALLY a Final Rule!
Hide Content
Questions and Answers
Hide Content


John Burnett
John Burnett

John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking, and is also a graduate of the BAIs and the Massachusetts Banker Associations Schools of Banking.

John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He joined Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company.

John joined Glia Group, Inc. and the team in June, 2004. He is a frequent presenter of BOL Learning Connect webinars, and at BOL Conferences events.

He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and a former member of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force as Regulation DD was being written, and has served on several ABA and Massachusetts Bankers seminar panels.