LPO

I would appreciate some guidance in the area of LPOs. It's not a branch for CRA, but does it need FDIC signage on the door or lending notices? Can the BB officers transport deposits to a branch for the customer? And any other tips would be appreciated.

KK,
Having just donne research into this topic, I can venture a fairly well educated opinion on this.
To your question about signage, I would say no to FDIC, yes to lending signage.

As to your question about deposits, I would say NO to anything resembling the deposit side of the banking business.If you start doing that, you had better be thinking about putting in a branch application.

According to the OCC in OCC-BC-199 Loan Production Offices and Interpretive Ruling 7.7380, 12 C.F.R. §§ 7.7380, the following activities are NOT permitted at an LPO:

1) the signing or accepting at the LPO of notes, security agreements, or other instruments obligating the loan customer to the bank;

2) delivery of loan proceeds to the customer at the LPO;

3) provision at the LPO of forms enabling the customer to open checking or savings accounts by mail;

4) counseling of customers at the LPO regarding savings accounts, checking accounts, use of CBCT's, or other bank services (apart from loans);

5) advertising stating or implying that the LPO provides more than loan origination services;

6) providing information to bank customers at the LPO concerning the status of their deposit accounts;

7) charging, or providing for the charging of, interest on loans running from a date prior to the time at which the proceeds of the loan are actually disbursed to the customer;

8) acceptance of loan payments at the LPO.

The follwing are the only permissable activities permitted at a LPO:

1) solicitation of loan business, including by means of advertisements disclosing the nature and limitations of the LPO;

2) providing information as to loans rates and terms;

3) interviewing and counseling of applications regarding loans (only), including the provision of disclosures required by regulations such as Regulation Z of the Federal Reserve Board;

4) aiding customers in the completion of loan applications.

Hope this helps.
Leslie

Leslie,

Thanks for your help.

Karen