I doesn't make sense, does it? Banks in Guam, Northern Marianas Islands and American Samoa are banks under the FDI Act, so I don't see why the Fed says they aren't banks for the Reg CC definition. It seems contradictory. Look at 229.43 for special rules on checks from those locations.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8