We applied for a "branch location" and now we want to call it Westcliffe Bank is that okay or do we have to call it Westcliffe Branch of Fremont National Bank? We did not apply for for a new "bank" just a branch. We are OCC regulated if that makes a difference.

Your sign should read "Fremont National Bank." If you want to call it "Westcliffe Bank", you would have to apply to be a new bank.

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you would have to apply to be a new bank.

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Not necessarily. You could establish a dba and have it Westcliffe Bank, N.A, a Division of Fremont National Bank. You need to check with the OCC on this and make sure you are OK with the FDIC, but I have seen it done.

And I learn something new everyday!

You might want to send Andy Z a PM as I believe his bank use to do something like this.

There was an interagency statement on this. FIL 46-98 is the one I saved. In part, it says:

The Interagency Statement urges banks and thrifts that intend to use a different name for a branch or other outlet to take reasonable steps to ensure that customers will not incorrectly assume that the branch or outlet is a separate institution from the bank or thrift, or that deposits in the different facilities are separately insured.

So this is doable with a dba, but you'll spend a lot of time ensuring that the customer knows what bank their account is really with.

Out of curiosity, why would a bank want to do this?

In our case we were expanding rapidly and had a common name that could cause confusion with banks already established in the new areas. So we had a dba that was used for the expansion (in-store) branches.

The FIL I cited was prompted in part when many banks were also venturing on to the net and they wanted a separate name from that which was traditionally used. They didn't want the same "branding" because the products and or fees may have varied.

One reason is to create the illusion that the branch will provide the same high-touch personal service as a true community bank.

I worked at a large bank that rolled merged institutions under one charter but kept the other names as "dba's" for marketing reasons. Until we all got sick of it, the expense, explanations, etc. and finally dropped the "dba's".

Thanks for the 411. I do remember seeing an internet bank that had a different name for its brick and mortar branches. The only way I knew the difference was by looking them up on the FDIC website. I wondered how they could do that. I thought it looked kinda fishy, so I wouldn't have put my money there. I imagine others would have thought the same, if they knew where to look. It seems like a hassle to me, but I'm an auditor. What do I know?

That being said, we are currently having a similar name problem. I work for a bank with a very common name. Another bank from another city has the same name as us, except for "& Trust" at the end. They opened a branch in town where we have a lot of customers, but no location. Our signage is different, but our customers and theirs are constantly getting us mixed up. We protested to our regulator, but they say there is nothing that they can do. It's a mess.

FYI - I just found out that it is not legal in Louisiana for a state chartered bank to do this. Therefore, I was right (in LA, anyway ). If you want 2 different names, ya gotta have 2 different charters.

Just thought you would like to know.