We are beginning the process of researching how we might go about accepting deposits for our customers at each of our affilate banks. We have 11 separately chartered banks and have seen a need to be able to accept one bank's customer's deposits at another of our banks. I've been trying to think of all the potential regulatory/security problems we might have and was wondering if someone out there who is already doing this could share your experience. I think my brain is on overload at the moment.

12 USC §1828 deals with affiliate relationships. Look down to (r). Basically, the law will allow Bank A to act as an agent for Bank B that is, you can receive deposits, renew CD’s, close loans, service loans and accept loan payments. The agreement can be one-way or reciprocal. The Fed has noted that there are two items specifically not allowed, establishing new accounts and the disbursement of loan proceeds.

I belong to a holding company that has 10 bank affiliates. Andy is very correct in his response, as security, we can not view customer accounts other than our own. If this fits your situation,cash back limits should be established.

Where can I find the FRB rule that affiliates cannot establish new accounts and disburse loan proceeds?