The Clearing House Association submitted a comment letter to the Fed regarding proposed changes to Reg CC to facilitate the continuing transition to fully electronic check clearing and return. Key changes include making the duty of expeditious return contingent upon a depository bank’s willingness to accept electronic returns, permitting a paying bank to require the same day settlement items be presented electronically, and expanding certain check warranties to cover paperless remotely created checks. TCH’s comment letter focuses on two issues: check fraud liability and the legal status of paperless remotely created checks.