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Open Accts At 0 Balance for DD of Employee Payroll

When presenting our banking products for employees at a place of business, can we open bank accounts at zero balance for direct deposit of employee payroll? Will we need FDIC signage?

Answer from Randy: If you are a State bank, you will have to check to see if this activity constitutes mobile branch banking.


Answer from Andy: "Branch" is defined in 12 USC 1813(o) as a location where deposits are received, checks paid or money lent. You are doing none of those so you do not have a "branch." Subject to any state law to the contrary I'd recommend "opening the account" at the remote location, but not finalizing it. Upon return to the bank, the bank deposits a penny into the account so that it may be opened (assuming you need more than $0) and waiving any low balance fee for the first month. Any documents needing to be delivered can be mailed if need be. You wouldn't need FDIC signage at the remote location as no deposit is accepted there. Advertisements on site would need "Member FDIC" or an acceptable replacement.

First published on 3/25/13

First published on 03/25/2013

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