We have an accountant interested in RDC for the purpose of making deposits into accounts they handle for various customers. While this is operationally possible, we don't know if we should allow it as a matter of policy. Our biggest concern is staff at the accounting firm selecting the wrong account to deposit funds into, a situation that we would not be able to prevent. Any thoughts on whether we should even allow this? If so, should we obtain RDC agreements from each of the individual customers, making sure to include a clause that releases us from liability if an error occurs?

From the standpoint of BSA, you are coupling the risks of remote deposit capture with the risks of banking a "professional service provider" as described in the BSA Manual. The practical equivalent would be in providing remote deposit capture to a law firm for it's IOLTA account.

I'm familiar with accounting firms offering "impound" accounts where their clients funds are deposited to assure the payment of tax liabilities. (The CPA wants to "know" they were paid before signing a form that says they were paid.)

Why is this accounting firm handling customer funds?

Are you allowing the accountant to make deposits in the branch in this capacity? Do you have any way of preventing this from going to the wrong account (assuming the teller is looking at how each check is written and endorsed and deposit slip?).

If you agree to allow it, then your contract should cover specific cases where they deposit incorrectly and the steps each is responsible for taking to fix.

You also need to review this to make sure this accountant is not acting as a money transmitter.

http://www.fincen.gov/news_room/rp/rulings/html/FIN-2012-R004.html

One of the mitigating controls on depositing checks into the inappropriate accounts is a strong deposit review program by the bank. The stronger your program, the less concerned you might need to be about that type of error/misapplication of funds. And conversely, if your control is less effective, the risk of errors/misapplication goes up.