Academic journal article ABA Banking Journal

A Branch by Any Other Name

Academic journal article ABA Banking Journal

A Branch by Any Other Name

Article excerpt

Q. Our bank's legal name does not include a geographic identifier, so for branches in locations that have a bank with a similar name, we use a dba ("doing business as") name. Most of our facilities use "XYZ Bank dba ABC Bank"; however, we are concerned that some of our forms, deposit slips, etc. might not have both the full bank name and the dba name. I heard that the agencies issued a joint policy statement on branch names on May 1. Will we run into problems with examiners? -- A.Z., TX

A. The joint policy statement advised financial institutions that use a different name for a branch or other facility (including the Internet) to "take reasonable steps to ensure that customers will not become confused and believe that its facilities are separate institutions or that deposits in the different facilities are separately insured." That includes using the legal name of the insured institution for legal documents, certificates of deposit, signature cards, loan agreements, account statements, and other similar documents. 0CC staff, both at the regional level and in Washington, suggested that you use the full name on all forms, whenever you reprint them. Although the policy became effective on July 1, you would not need to destroy any old forms-you should just have adequate procedures in place to ensure compliance in the future.

The guidelines also recommend that you check your signage and advertising; educate your staff; and ask new depositors to sign a statement regarding deposit insurance. …

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