Sorry to be beating the same old drum, but I need confirmation or to be corrected...

Bank A in Fed District 5 (Charlotte) has acquired Bank B in Fed District 6 (Head Office). Bank B will retain same routing number - 0611 and send items to be processed through Bank A's check processing region.

Assumptions: Banks within geographic location of Fed District 6 (Head Office)with routing numbers listed in Appendix A will still be local to Bank B and Bank B will be local to them. These same banks will be non-local to Bank A.

Am I making too much of this - sounds like things stay the same except for the "on-us" relationship between Bank A and Bank B?

Thanks for your help!

Thanks, John! Bank A and B (same bank after merger) are in different states and different check processing regions, so if we don't treat it as an on-us check, how do we treat it if a customer from Bank B deposits a check in Bank A?

I feel like I'm thinking about this way too hard. The Big Banks do this all the time.

Ann

They are permitted (not required) to treat each other's checks as non-local items.

If your bank wants to, it certainly MAY consider checks on its Georgia branches as on-us items, and vice versa. If and when you are able to run the Carolina and GA banks as one, you might want to do that, even though you would not be required to.

That's what I thought - sounds so simple when you say it!

So are you saying, if a bank has a branch in district 1 and another in district 2, both under the same bank name/charter/whatever, they can treat each other as foreign??

Not foreign. Non-local. If the branches are in both different check processing regions and in different states, they can ignore the fact that they are part of the same bank.

Banks in Shreveport and New Orleans cannot use this exception because they are both in the same state. And Shreveport branches of Texas banks can't use it because they're all in the Dallas check region.

But think about B of A branches in Massachusetts and those in California. B of A could treat checks drawn on branches in Massachusetts and deposited in a B of A branch in California as non-local items.

The term "on-us" isn't used in Reg. CC. Look at 229.10(c)(1)(vi).