However, if you are asking if you can form a deposit production office, a DPO is not a branch. The OCC states as follows:
§ 7.4004 Establishment and operation of a deposit production office by a national bank.
(a) General rule. A national bank or its operating subsidiary may engage in deposit production activities at a site other than the main office or a branch of the bank. A deposit production office (DPO) may solicit deposits, provide information about deposit products, and assist persons in completing application forms and related documents to open a deposit account. A DPO is not a branch within the meaning of 12 U.S.C. 36(j) and 12 12 CFR 5.30(d)(1) so long as it does not receive deposits, pay withdrawals, or make loans. All deposit and withdrawal transactions of a bank customer using a DPO must be performed by the customer, either in person at the main office or a branch office of the bank, or by mail, electronic transfer, or a similar method of transfer.
Basically, much like a loan production office, this is not considered a branch as long as no branch activities take place there. (Response provided March 2017.)Q: We’ve noticed that sometimes payee names on the final invoice we receive from the title company do not match what we have on the closing disclosure. Where in the rule does it specify that we are responsible for providing the exact payee names as they are listed on the title company invoice? A: I believe the commentary below is what you are looking for. This appears to be a clerical error that should be corrected within the specified timeframe if the payee name is incorrect. I suggest contacting the title company explaining the additional work this is causing your bank to determine a better way to ensure you are receiving the correct names for the payees going forward.
Commentary to 1026. 19(f)(2)(iv)-
1. Requirements. Section 1026.19(f)(2)(iv) requires the creditor to deliver or place in the mail corrected disclosures if the disclosures provided pursuant to § 1026.19(f)(1)(i) contain nonnumeric clerical errors. An error is considered clerical if it does not affect a numerical disclosure and does not affect requirements imposed by § 1026.19(e) or (f). For example, if the disclosure identifies the incorrect settlement service provider as the recipient of a payment, then § 1026.19(f)(2)(iv) requires the creditor to deliver or place in the mail corrected disclosures reflecting the corrected non-numeric disclosure no later than 60 days after consummation. (Response provided March 2017.)
Answers are provided by LESLIE CALLAWAY, CRCM, CAFP, director of compliance outreach and development; MARK KRUHM, CRCM, CAFP, senior compliance analyst; and RHONDA CASTANEDA, CRCM, compliance analyst, ABA Center for Regulatory Compliance. Answers do not provide, nor are they intended to substitute for, professional legal advice. Answers were current as of the response date shown at the end of each item.