In a letter dated May 21, the FDIC told CEOs and CIOs to begin planning for operational changes needed to implement Check 21. The FDIC regulates more than 5,000 small savings and loans and state-chartered banks, many of which lack image-handling capabilities.
To accommodate them, Check 21 lets banks transmit check images to service providers near the banks against which the checks are drawn. There, check images are printed as facsimiles and hand-delivered to the receiving banks, thereby saving the sending banks the cost of transporting original paper checks.
The FDIC letter calls on its member banks to begin training staff to deal with myriad Check 21-related customer-service issues. For example, if a customer questions the validity of a facsimile of a check, the bank must credit the customer's account. If the original check was destroyed and a better copy can't be located, then the bank that converted the check into an image bears the loss.