Efforts by community banks to convert to an all-image check-clearing environment are almost complete. In 2011, 87 percent of the community banks deposited their cash letters electronically, and 4 percent planned to implement image cash letter deposit by 2013, according to The ICBA 2011 Community Bank Payments survey. The remaining 8 percent had no plans to implement the process before 2013. Additionally, 89 percent of community bankers polled said they received their cash letters electronically, 3 percent planned to implement image cash letter receipt by 2013, and the remaining 9 percent had no plans to implement the process before 2013, according to the survey. According to that survey the community banks that did not plan to adopt image cash letter deposit (8 percent) and receipt (8 percent) would have been subject to the eroding service levels and higher costs associated with paper check clearing and generally had $250 million in assets or less.
- ICBA supports the Federal Reserve’s proposed expeditious requirement framework, but opposes warrant exceptions when collecting and presenting banks agree to accept items not meeting the definition of an electronic collection item or electronic return.
- ICBA strongly supports the Federal Reserve’s proposal for paying banks to have the prerogative to require that all same‐day settlement presentments be delivered electronically and urges adoption of clarifications regarding paying banks’ same‐day settlement requirements in an electronic presentment environment.
- ICBA recognizes and supports the Electronic Check Clearing House Organization (ECCHO) rules for electronic check presentment and check image exchange, and the NACHA Operating Rules for the ACH network and check conversion.
- ICBA promotes check electronification by raising banker awareness, providing banker and customer educational resources, and identifying the necessary steps community banks can take to effectively prepare and respond to processing changes.
Reducing the industry’s dependence on a paper check-processing infrastructure is vital as the Federal Reserve Banks and other service providers downsize check operations in response to declining paper check volumes. As paper check volumes continue to decline, per-check clearing costs will accelerate due to the fixed-cost infrastructure supporting the paper-based clearing and settlement process. Additionally, check electronification models (Check 21, image exchange, electronic check presentment and electronic check conversion using the ACH network) bring faster clearing, improved fraud detection capabilities, and improved efficiency by reducing equipment, staffing and transportation costs.