CUNA joined with other financial service organizations in filing a comment letter with the Federal Reserve Board regarding a proposed revision to Regulation CC.
The revision seeks to create a presumption of alteration for any dispute over whether the dollar amount or the payee on a substitute check is derived from an original check that is a forgery.
“The commenters support a presumption of alteration in Regulation CC as preferable to presumption of forgery,” the letter states. “We believe that alteration of a legitimate check is the more common type of check fraud today in which disputes arise between banks, and therefore a presumption of alteration in those disputes when evidence lacking is appropriate.”
Among the areas the letter addresses are:
Other organizations signing the letter include American Bankers Association; The Clearing House Payments Co., LLC; Electronic Clearing House Organization; Independent Community Bankers of America; and National Association of Federally Insured Credit Unions.