Off-site banking? When does it become a branch?

At what point does conducting business outside of a traditional branch become a new branch and require regulatory approval? In the past, the bank has gone to schools and opened accounts, and that doesn't seem to be a problem. They have also accepted deposits off-site for short periods of time. Now, they propose to go to a particular site (e.g., retirement home) twice a month for a few hours, to accept deposits and cash checks. Aside from security issues, is this a problem? When does it become a "branch"?

Thanks!

For HMDA purposes a "branch" is any office that has been approved as a branch by any federal or state agency, but does not include free-standing terminals such as ATM's, loan production offices, or offices of affiliates or other third parties such as loan brokers.

That's only for HMDA purposes though. Are you trying to find out for a specific reason?

A branch is any facility that takes deposits, cashes checks or lends money.

It would appear you have a branch in both instances you mention above.

You should check your state laws and the requirements of your federal regulator. For a national bank, you would need to have approval and comply with record keeping requirements for a mobile branch for all of the situations you cited.

Thanks for the help. I was able to find the answer I needed in state banking regs.