Facilty not Open to Public

Posted By: JustGottaKnow

Facilty not Open to Public - 03/23/11 01:57 PM

We have a loan production office in a county that is not in our assessment area. The office wants to start taking deposits and payments for those customers that they are doing loans for. We are wanting to file with the FDIC that this is a full service brick and mortor office. I know that we will have to expand our assessment area to include this new 'branch' location; however, my concern is that the facility will not be open to the public and will be the only branch facility in this county. Can anyone tell me what impact this might have on the service test?
Posted By: Karen Tucker

Re: Facilty not Open to Public - 03/24/11 01:46 PM

It really depends on whether it becomes a legal branch and what services are offered there. REG says for retail services performance: (d) Performance criteria--retail banking services. The OCC evaluates the availability and effectiveness of a bank's systems for delivering retail banking services, pursuant to the following criteria:
(1) The current distribution of the bank's branches among low-, moderate-, middle-, and upper-income geographies;
(2) In the context of its current distribution of the bank's branches, the bank's record of opening and closing branches, particularly branches located in low- or moderate-income geographies or primarily serving low- or moderate-income individuals;
(3) The availability and effectiveness of alternative systems for delivering retail banking services (e.g., ATMs, ATMs not owned or operated by or exclusively for the bank, banking by telephone or computer, loan production offices, and bank-at-work or bank-by-mail programs) in low- and moderate-income geographies and to low- and moderate-income individuals; and
(4) The range of services provided in low-, moderate-, middle-, and upper-income geographies and the degree to which the services are tailored to meet the needs of those geographies.

You will want to develop a good performance context for the area.