Is there any guidance that will officially deter us for offering remote deposit capture to MSBs?

No. It is discouraged, but ultimately acceptable. However, our regulators have said we need to review all deposited items made by the MSBs.

I have talked with FinCEN about a fairly new customer using remote capture products offered by another company. FinCEN would not give a definitive answer but strongly suggested the feasibility of retaining the account and the risk involved be reviewed. The person I talked to said this is a new area for them and had to talk to several supervisors.

Some remote capture products also offer remote review and approval. You may want to contact Jana Waughn at RemitPro. They have great products, seamless installation and good response times for client needs. They offer both CIP and Remote Deposit products. Remote response time on the CIP product is 8 seconds - I suspect that the remote deposit is the same. You can tell her Aaron Fox referred you if she asks.