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#18221 - 05/20/02 06:23 PM Name of Bank Branch Parent in Advertisements
JulesB Offline
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JulesB
Joined: Feb 2002
Posts: 324
A Designated Tree City in OK, ...
Our bank has a branch in another state, that operates under another name. Do print advertisements for this branch need to state that they are "a branch of ABC bank, city, state", or can they just show their operating name in their ads? I have not been able to locate a reg, if there is one, covering advertising the name of the lead bank.
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General Discussion
#18222 - 05/20/02 06:31 PM Re: Name of Bank Branch Parent in Advertisements
PatriciaC Offline
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PatriciaC
Joined: Oct 2001
Posts: 192
Lewisville, Texas, US
If you are referring to a "branch" vs. a separately chartered subsidiary, then the FDIC's FIL 46-98, "Guidance on the Use of Trade Names" is where you need to look. This is an interagency statement that provides some specific steps you should consider. The following in an excerpt:

"While there are no federal laws or regulations that specifically require that all branches of an insured depository institution operate under a single name, the Agencies are concerned that if customers believe they are dealing with two different institutions, they may inadvertently exceed FDIC insurance limits by depositing excess amounts in different branches of the same. The Agencies believe it is important that customers understand the scope of FDIC insurance in these circumstances. Accordingly, an insured depository institution that intends to use a different name for a branch or other facility should take reasonable steps to ensure that customers will not become confused and believe that its facilities are separate institutions or that deposits in the different facilities are separately insured."
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Patricia Cashman,CRCM
Cashman Compliance Solutions, LLC
This is NOT legal advice

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#18223 - 05/20/02 06:39 PM Re: Name of Bank Branch Parent in Advertisements
JulesB Offline
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JulesB
Joined: Feb 2002
Posts: 324
A Designated Tree City in OK, ...
Thanks for the quick input! We made sure that all of the printed materials (disclosures, bank statements, brochures) relating to deposit accounts do state that the branch is just that, and have the name of the bank included. The ad in question talks about real estate lending for construction, commercial, and home loans.
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#18224 - 05/20/02 07:04 PM Re: Name of Bank Branch Parent in Advertisements
PatriciaC Offline
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PatriciaC
Joined: Oct 2001
Posts: 192
Lewisville, Texas, US
Then you should be in the clear. The only concern by the regulators is for deposits.
_________________________
Patricia Cashman,CRCM
Cashman Compliance Solutions, LLC
This is NOT legal advice

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