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#506180 - 02/28/06 08:58 PM Bank at school program
COMPLIcated Offline
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Joined: Mar 2003
Posts: 1,035
OK
Could someone guide me to where I can check on rules and guidelines regarding bank employees taking deposits at on site locations such as schools?

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Operations Compliance
#506181 - 02/28/06 09:08 PM Re: Bank at school program
Lestie G Offline

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Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
This will require a mobile or temporary branch charter. Check out the OCC's branching publications here.
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#506182 - 02/28/06 10:12 PM Re: Bank at school program
COMPLIcated Offline
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OK
I meant at an elementary school where we are there just one morning a week to take their savings deposits and then bring them back to the bank to deposit. I did not mean a college or university.

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#506183 - 02/28/06 10:39 PM Re: Bank at school program
Lestie G Offline

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Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
I understand - we have the same thing going on here. If you're going to accept deposits anywhere but at your branch locations, you need a mobile branch charter to do so.
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Opinions my own.

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#506184 - 03/01/06 07:13 PM Re: Bank at school program
OkieOps Offline
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OkieOps
Joined: May 2001
Posts: 752
OK
You will need to check your state banking code. We were involved with this program when it first came out. Our state bank code explicitly states that this activity for "educational purposes" shall be permissable and not considered a branch. I had to look it up and explain it to a parent who happened to be an attorney.

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#506185 - 03/02/06 09:46 PM Re: Bank at school program
QueenBB Offline
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Joined: Jan 2006
Posts: 190
TX
Our bank did the exact program you are talking about--just take deposits at the school once a week. We wrote a letter to our examiners and told them what we planned to do and asked if there was anything we needed to do with them. They told us nothing was required; but thought it was a great idea. I would suggest writing your examiners and asking for guidance.

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#506186 - 03/03/06 04:04 PM Re: Bank at school program
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
As NancyC suggests, check with your state bank supervisors, if you are not a federally-chartered bank. Some states make it exceptionally easy to set up in-school banking programs; others place a lot of hurdles in the way.
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BankersOnline.com
Fighting for Compliance since 1976
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#506187 - 03/03/06 07:50 PM Re: Bank at school program
COMPLIcated Offline
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Joined: Mar 2003
Posts: 1,035
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Yes, thank you everyone! We talked to our state banker's associations legal counsel and they referenced the same state banking code that allows us to do this for educational purposes so I think we are okay.

Nancy C. - we also had a parent that was an attorney (and banked somewhere else) and was the one to question our program. First time since it's inception almost 9 years ago!

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#506188 - 03/03/06 08:21 PM Re: Bank at school program
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
National banks must apply for a mobile branch charter (an easy process) and maintain logs of all visits to the off site locations. The OCC also required that we notify our state dept of banking in NJ, which has a mobile banking law. It was not required, but the OCC asked that we do it to maintain good relations between the state and national banks. That consisted of one letter.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#506189 - 03/04/06 03:16 PM Re: Bank at school program
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
For the record, although others may find the discussion on national bank requirements useful, Shannon's bank holds a state charter.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#506190 - 03/04/06 06:54 PM Re: Bank at school program
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
I felt it worth clarifying for those who have a national bank charter who may find this later via a search so they are don't get too excited and go astray!
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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