We believe that if a bank employee picks up deposits, that would constitute “accepting” a deposit; but if a third party service picked up deposits, that would not constitute accepting a deposit. The 1994 letter your referenced draws a line between (1) a bank using its own employees to pick up deposits from customers to be credited to the customers’ accounts when received at the bank’s premises, which would constitute accepting deposits, and (2) a bank using a third party service to pick up deposits to be posted to the customers’ accounts when the deposits are delivered to a bank, which would not constitute accepting deposits. Interpretive Letter 94-25 (December 1, 1994). The letter also adopts the OCC rule on messenger services and applies the rule to Illinois banks. The OCC rule also states that banks must use third parties for messenger services to avoid branching restrictions and provides for a safe harbor for third party messenger services, as set out in the 1994 letter. Id.12 CFR 7.1012. Under the interpretive letter and the OCC rule, if bank employees take deposits for delivery or at an LPO, that could be considered accepting deposits, and the LPO or courier service would be considered a branch.