Probably covered already but I'd like to know. We do not have RDC for customers. We have our branches capturing the the deposit information and then sending to the Main Office for deposit and Check Image processing to the FED.
Someone said they were at a presenatation that said these were to be considered RDC's

The recent guidance was directed at risk mitigation for Remote Deposit Capture from customer locations -- not from remote bank locations.

this is branch capture, not remote deposit capture. Two different issues.

I would suggest that you re-read the guidance document. While it presents different risks, a risk assessment would still be required. From the first sentence of the guidelines:

Background and Purpose

Remote Deposit Capture (RDC), a deposit transaction delivery system, allows a financial institution to receive digital information from deposit documents captured at remote locations. These locations may be the financial institution’s branches, ATMs, domestic and foreign correspondents, or locations owned or controlled by commercial or retail customers of the financial institution.

The guidance in the first paragraph says it includes a financial institutions branches, atm's, commercial customers, etc.
The BOL webinar which I missed also said (and plan to order on CD)Critical points about the guidance …

The guidance covers not just Remote Deposit - Merchant Capture

It also covers:
Branch Capture
Teller Capture
And even mobile banking and more!!!

Though when I read the guidance it only made reference to how to secure merchants.

Sorry Ron had it covered!!