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Is a night deposit box allowable? What if a courier picked up deposits after hours? – IBA Compliance Connection

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Is a night deposit box allowable? What if a courier picked up deposits after hours?

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A night deposit box is certainly allowable, but it would be considered a branch (unless it is connected to an ATM). Interpretive Letter 94-10 (June 15, 1994)92-4 (May 14, 1992). Any deposit receptacle would clearly be “accepting deposits,” but an ATM would be exempt from the definition of “branch.” Id.205 ILCS 5/5b.

A third-party courier service would not be considered a branch, and this would not be affected by the timing of the pick-ups or deliveries. The Illinois DFPR has adopted the OCC rule on couriers, which is that third-party couriers (which pick up deposits and deliver them to the bank) are not considered branches. Interpretive Letter 94-25 (December 1, 1994)12 CFR 7.1012(c)(1).