Answer:
A loan production office that doesn't accept deposits and isn't a branch doesn't need FDIC signage or Reg CC availability policies. Your Equal Housing Lender poster should be there, as it is required where deposits are received or where loans are made. For simplicity, I would also post my CRA and HMDA signs (if applicable), but you could argue that since this is not a branch, they're not required. Still, post it and forget it, is easier than defending why it isn't there later. We have other things to worry about.
If you are accepting an employee's deposit, you may well have an unauthorized branch in addition to the signage requirements. Two things that come to mind in this case is that a disgruntled ex-employee can be your worst nightmare, when complaining to regulators or others about these practices, and unless you are very clear that these items are being sent to a mail teller who will process them at the real branch, and they are not considered deposited at the loan production office, you need to read my first concern again.
First published on BankersOnline.com 5/24/10
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