What is a Branch?

The FRB's amendments to Regulation H clarify when a service location is not a branch. The FRB acted to make Regulation H consistent with OCC interpretations by providing that an office of an affiliated or unaffiliated institution providing services to customers on behalf of the bank is not a branch. If, however, the bank establishes or operates the office providing the services, it would be a branch. It comes down to a question of who runs the office, or who is actually in charge.

Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3, No. 11, 8/98