QUESTION: My bank is thinking about starting a courier service that would pick up deposits from customers at their homes or places of business. What compliance issues do we need to consider in starting up such a service?
ANSWER: Your compliance issues will depend on whether your institution is a State or National Bank. The OCC which
regulates National Banks considers a bank operated courier service a branch of the bank since deposits will be picked up. A branch application is required and approval must be granted prior to the start of the courier service. If you are a State bank you may or may not be required to submit a branch application depending on your state law and the regulations of your state regulatory agency. I suggest you contact the appropriate regulator to determine what action if any is required to establish the courier service.
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