For several years, CheckImage Central has provided statistics on the transition from paper checks to image exchange. These statistics include transit items that are settled through the Federal Reserve, Viewpointe, The Clearing House, selected ECCHO Full and Participating Members and other local / regional exchanges.
Since Check 21 became effective in October 28, 2004, the adoption of image exchange has been faster than expected. Forward presentment of checks by image was nearly 100% by 2010. Image returns have been a little slower to reach universality. The Federal Reserve Board seeks to encourage the final group of financial institution holdouts to accept electronic returns by adding a new liability approach in Reg. CC (Section 229.33(a)) to encourage depositary banks to accept electronic return checks. Under this new provision, a paying/returning bank is liable to the depositary bank for failing to meet the Reg. CC expeditious return rule (Section 229.31(b)) only if the depositary bank has arrangements for return of checks electronically by “commercially reasonable means.”