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#2186710 - 07/25/18 01:44 PM Drive Through Only Branch Disclosures
beegee Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,095
South
What branch disclosures are required for a drive through only branch?

Is it just the FDIC signage?
Last edited by beegee; 07/25/18 01:45 PM.
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General Discussion
#2186727 - 07/25/18 02:23 PM Re: Drive Through Only Branch Disclosures beegee
Monster Offline
Gold Star
Joined: Sep 2015
Posts: 479
Does it accept deposits? Reg CC. I'm curious how "lobby posters" would be treated in this scenario? Never thought about it.

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#2186730 - 07/25/18 02:25 PM Re: Drive Through Only Branch Disclosures Monster
beegee Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,095
South
It does accept deposits but does not open new accounts or loans.

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#2186731 - 07/25/18 02:30 PM Re: Drive Through Only Branch Disclosures beegee
Monster Offline
Gold Star
Joined: Sep 2015
Posts: 479
Just found an exemption for drive thru's and funds availability - learn something new every day.

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#2186990 - 07/26/18 05:49 PM Re: Drive Through Only Branch Disclosures beegee
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Correct that Reg CC does not require the notice to be posted at drive up windows. I believe you only need "Member FDIC"signage.
_________________________
David Dickinson
http://www.bankerscompliance.com

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#2187069 - 07/27/18 01:19 PM Re: Drive Through Only Branch Disclosures beegee
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,628
Agreed. From the commentary to 229.18(b) of Regulation CC:

"The notice is not required at any drive-through teller windows nor is it required at night depository locations, or at locations where consumer deposits are not accepted."
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2187398 - 07/30/18 09:18 PM Re: Drive Through Only Branch Disclosures beegee
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
We have two of these facilities and only display the Member FDIC signs. We used to include some of the other lobby disclosures but decided not to since not required and to clear up "clutter" in the window.

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