Topic: Deposit Brokers
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One of our customers died two years ago. An estate representative came to the bank and closed the customer’s deposit account last year. The teller who closed the account neglected to inform the estate representative that the customer also held a safe deposit box, which remains open. The teller also neglected to collect the estate representative’s contact information. Can we drill the box and remit the contents as unclaimed property? Or does the estate representative’s visit count as an activity?
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Yes, we believe that your bank may report and remit the safe deposit box property to the Treasurer’s office under the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA). As a general rule, safe deposit box property is considered unclaimed five years after the expiration of the lease or rental period for the box. But…
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If we would like to start a relationship with a company that has a website that would send potential depositors to our website, with payment for each referral, would that be considered a deposit broker relationship or a joint marketing relationship?
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We recommend that the bank consult with an attorney to determine the structure of its relationship with the company, either as a deposit broker relationship or as a limited marketing relationship. Deposit Broker Relationship We believe that the arrangement we discussed would be considered a deposit broker relationship. A “brokered deposit” includes any “deposit that…