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#586058 - 07/20/06 01:54 PM Courier Policies *DELETED*
coho Offline
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Joined: May 2005
Posts: 40
Post deleted by Walker

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#586059 - 07/21/06 03:44 PM Re: Courier Policies
mck401 Offline
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Joined: May 2006
Posts: 1,168
Texas
Not to ride on your coat-tails, however, I am looking for the same guidelines if anyone can share.
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#586060 - 07/24/06 03:18 PM Re: Courier Policies
coho Offline
Junior Member
Joined: May 2005
Posts: 40
mck401,

I'm not getting any responses. I even posted it under the HR area and nothing. Lots of looks - so people are interested - but no insight to what others are doing.

I think we are going to go to the bank attorneys and see what they can find. I was hoping to have something to start with before I talked with them.

If you hear from anyone by PM could you share?

Thanks

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#586061 - 07/24/06 03:42 PM Re: Courier Policies
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
We currently have a courier in one of our markets doing what y'all describe, but we have not set policy regarding his activities - however, should either of you wish to PM I could give you our best practices and how we currently manage that program.
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#586062 - 07/24/06 11:17 PM Re: Courier Policies
Don_Narup Offline

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Posts: 3,708
Las Vegas Nevada
One reason you may not be getting responses is that unless you have done this very carefully, banks are not licensed to take deposits anywhere but at a branch office location. Which is why regulations require the use of third parties to act as couriers.
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#586063 - 07/25/06 01:04 PM Re: Courier Policies
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Which is why our courier is actually has a mobile branch designation - of course we're in Texas and it may depend on your state how you should handle that aspect.
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#586064 - 07/25/06 01:41 PM Re: Courier Policies
coho Offline
Junior Member
Joined: May 2005
Posts: 40
Don,

We have done our home work on setting up our courier service. It has been blessed by the regulators.

I'm just looking for some insight on how a driving record can be used in the hiring\firing part of the job.

Thanks for your response.

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#586065 - 07/25/06 03:05 PM Re: Courier Policies
blue Offline
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Joined: Jul 2005
Posts: 793
Don,

Could you cite the specific regulation? We are FDIC supervised. Thanks.
Last edited by blue; 07/25/06 03:55 PM.
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#586066 - 07/25/06 03:10 PM Re: Courier Policies
Lestie G Offline

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Joined: May 2002
Posts: 3,606
Near the Land of Enchantment
I don't have a sample policy for you, but a suggestion. If you haven't already, contact your bank's insurance agent to find out what they expect and what they'll cover in relation to this mobile branch charter (which is what you've got if the regulators have blessed it). The company might have some documented minimum standards for driving records, vehicle security, etc. that you'll need to be sure you address in your policy.
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#586067 - 07/25/06 04:09 PM Re: Courier Policies
Don_Narup Offline

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Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
Blue - Check FDIC 97-6 issued 9/26/97 This was cited a few months ago in response to a similar question

I believe in Texas you have to have a designated Mobile Branch pick up deposits off site. Do a search of BOL Ther are a number of posts on this issue.

For national banks, the contract must be between the customer and the courier if the bank wishes to avoid needing approval and keeping records for a mobile branch.

So check your state laws as well as regulatory requirements.
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#586068 - 07/25/06 08:49 PM Re: Courier Policies
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
Blue Here is a better site

https://www.fdic.gov/regulations/laws/rules/4000-9860.html

It basically says:
In summary, it appears from the facts provided that the proposed courier/messenger services would include at least one of the core banking functions, i.e., receiving deposits, that the service would be established by the Bank, and that the service would provide the Bank a competitive advantage over other banks. As a result, such a service would be considered to be a branch and, therefore, would require the FDIC's prior consent under section 18(d)(1) of the Federal Deposit Insurance Act, 12 U.S.C. 1828(d)(1).
{{12-31-98 p.4984.22}}
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#586069 - 07/25/06 08:56 PM Re: Courier Policies
blue Offline
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Joined: Jul 2005
Posts: 793
Thanks Don. The actual law/regulation could be interpreted as meaning any transaction information, e.g. teller tickets. This seems to clarify th issue to the point that I can resume breathing!
Thanks again for your thoughtful assistance.

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