Thread Options
#1022235 - 08/18/08 06:40 PM Opening & funding online - require branch applic?
"Rita" Offline
New Poster
Joined: Apr 2008
Posts: 7
Utah, USA
Our bank is preparing to offer "online account opening & funding" for deposit accounts. We heard from a state chartered bank that this requires application and approval from your regulatory agency. I have researched 12 CFR 5.30(b & d(i & ii)) and am unable to determine if this really constitutes a Branch . We are OCC regulated. Does anyone have some guidance?

Return to Top
eBanking / Technology
#1022532 - 08/19/08 01:27 AM Re: Opening & funding online - require branch applic? [Re: "Rita"]
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 74,768
Galveston, TX
"We heard from a state chartered bank that this requires application and approval from your regulatory agency."

This may be a requirement for a State bank, but I am not aware that internet banking requires a branch application for a National Bank.

Under 12 CFR 5.30, I think it is just an extension of your main office charter.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1023323 - 08/19/08 07:19 PM Re: Opening & funding online - require branch applic? [Re: rlcarey]
1 Peter 5:7 Offline
Diamond Poster
1 Peter 5:7
Joined: Jun 2001
Posts: 1,339
TX
For the record and the benefit of others, OTS requires advanced notice in 12 CFR 555.300:

"You must file a written notice [with OTS] as described in Sec. 555.310 before you establish a transactional web site. A transactional web site is an Internet site that enables users to conduct financial transactions such as accessing an account, obtaining an account balance, transferring funds, processing bill payments, opening an account, applying for or obtaining a loan, or purchasing other authorized products or services."
_________________________
Opinions are mine not my employer's, and should not be taken as legal advice.

Return to Top

Moderated by:  Andy_Z