The Illinois Banking Act defines a “branch” as a place where “deposits are received, checks paid, or loans made, but shall not include any place at which only records thereof are made, posted, or kept.” 205 ILCS 5/2. The IDFPR interpretive letter you referenced states that a loan production office (LPO) that does not fall into that “branch” definition would not be subject to the application and notice requirements for branches (in addition to other restrictions that have since been repealed). Interpretive Letter 91-21 (September 4, 1991). As stated in that letter, permissible activities at an LPO include “explaining credit product features and benefits; assisting in credit application preparation; and accepting credit applications for referral to and processing at the bank” and that an impermissible LPO activity would be “approval or denial of credit applications.” Id. We would interpret the letter to allow for someone to take loan applications at the LPO, but the individual would have to refer the applications to the bank for underwriting, approval, disbursal of funds, etc.