Posted By: beegee
Drive Through Only Branch Disclosures - 07/25/18 01:44 PM
What branch disclosures are required for a drive through only branch?
Is it just the FDIC signage?
Posted By: Monster
Re: Drive Through Only Branch Disclosures - 07/25/18 02:23 PM
Does it accept deposits? Reg CC. I'm curious how "lobby posters" would be treated in this scenario? Never thought about it.
Posted By: beegee
Re: Drive Through Only Branch Disclosures - 07/25/18 02:25 PM
It does accept deposits but does not open new accounts or loans.
Posted By: Monster
Re: Drive Through Only Branch Disclosures - 07/25/18 02:30 PM
Just found an exemption for drive thru's and funds availability - learn something new every day.
Posted By: David Dickinson
Re: Drive Through Only Branch Disclosures - 07/26/18 05:49 PM
Correct that Reg CC does not require the notice to be posted at drive up windows. I believe you only need "Member FDIC"signage.
Posted By: Adam Witmer
Re: Drive Through Only Branch Disclosures - 07/27/18 01:19 PM
Agreed. From the commentary to 229.18(b) of Regulation CC:
"The notice is not required at any drive-through teller windows nor is it required at night depository locations, or at locations where consumer deposits are not accepted."
Posted By: ahkcompliance
Re: Drive Through Only Branch Disclosures - 07/30/18 09:18 PM
We have two of these facilities and only display the Member FDIC signs. We used to include some of the other lobby disclosures but decided not to since not required and to clear up "clutter" in the window.