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#533157 - 04/18/06 04:31 PM Off-site banking? When does it become a branch?
mariposa Offline
100 Club
Joined: Mar 2006
Posts: 220
the Golden State
At what point does conducting business outside of a traditional branch become a new branch and require regulatory approval? In the past, the bank has gone to schools and opened accounts, and that doesn't seem to be a problem. They have also accepted deposits off-site for short periods of time. Now, they propose to go to a particular site (e.g., retirement home) twice a month for a few hours, to accept deposits and cash checks. Aside from security issues, is this a problem? When does it become a "branch"?

Thanks!
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Sarah, CRCM

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Operations Compliance
#533158 - 04/18/06 04:42 PM Re: Off-site banking? When does it become a branch?
Beige Offline
Power Poster
Beige
Joined: Apr 2006
Posts: 3,950
For HMDA purposes a "branch" is any office that has been approved as a branch by any federal or state agency, but does not include free-standing terminals such as ATM's, loan production offices, or offices of affiliates or other third parties such as loan brokers.

That's only for HMDA purposes though. Are you trying to find out for a specific reason?
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“Where words fail, music speaks.” - Hans Christian Andersen

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#533159 - 04/18/06 05:22 PM Re: Off-site banking? When does it become a branch?
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
A branch is any facility that takes deposits, cashes checks or lends money.

It would appear you have a branch in both instances you mention above.
Last edited by joker; 04/18/06 05:24 PM.
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#533160 - 04/18/06 05:25 PM Re: Off-site banking? When does it become a bran
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
You should check your state laws and the requirements of your federal regulator. For a national bank, you would need to have approval and comply with record keeping requirements for a mobile branch for all of the situations you cited.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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#533161 - 04/18/06 06:13 PM Re: Off-site banking? When does it become a bran
mariposa Offline
100 Club
Joined: Mar 2006
Posts: 220
the Golden State
Thanks for the help. I was able to find the answer I needed in state banking regs.
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Sarah, CRCM

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