Topic: Permissible Bank Activities
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We are considering allowing one of our branches to serve as a polling place for a local Illinois election. The space that would be used is a meeting room with its own entrance to the outside. Are there any laws or regulations we should be aware of when determining whether to allow this?
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We are not aware of any law or regulation that addresses the use of a bank branch as a polling place. For the reasons stated below, we believe such a use may be permissible as a “non-banking” activity, provided adequate precautions are taken to secure the branch if polling is open beyond normal bank hours. …
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We acquired a bank that performs certain vehicle license services to customers and non-customers for a flat fee. For example, they issue temporary vehicle registrations. Can banks provide these types of services?
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Yes, Illinois law permits banks to issue vehicle registration plates and stickers, as well as conduct a variety of other vehicle registration and title services. The Illinois Secretary of State (SOS) has established an electronic registration and titling (ERT) program through which banks may contract with one of five approved service providers to transmit applications…
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We have a loan production office (LPO) in Illinois. Can we receive mail at an LPO, even if customers inadvertently mail loan payments there? What activities should we avoid?
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Under the OCC’s standards, receiving misdirected loan payments in the mail will not cause the LPO to be considered a branch. Also, while the IDFPR has not issued written guidance on this issue, we confirmed with an IDFPR attorney that it would not view occasional misdirected loan payments as causing an LPO to be treated…