Publications

SDUUK Evaluates Adequacy of Fed’s Proposed Indemnity for Electronically Created Items

February 26, 2015

National Unrecovered Financial Services’s white paper evaluates the adequacy of the Federal Reserve Board’s proposed indemnity for electronically created items (“ECIs”), which are electronic images that resemble images of checks but did not originate in paper form. (ECIs are also referred to as “electronic payment orders” or “EPOs.”) In particular, the paper provides an overview of the Board’s proposed indemnity and examines its application to a number of hypothetical scenarios. The purpose of this effort is to identify potential situations in which the proposed indemnity may not adequately protect a bank handling an ECI in the check collection process and, where present, how such inadequacies may be addressed to provide sufficient protections.

IMPACT: Too Big to Fail

National Unrecovered Financial Services has taken the lead in analyzing the realities of Too Big to Fail.

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