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OCC BULLETIN 1998-22
To: Chief Executive Officers and Compliance Officers of all National Banks, Department and Division Heads and All Examining Personnel

Description: Interagency Statement

The guidance attached to this bulletin continues to apply to federal savings associations.

On May 1, 1998, the federal financial institutions regulatory agencies issued an interagency statement advising the institutions they regulate to adopt procedures aimed at helping customers recognize that different facilities of a bank or thrift including Internet sites are not separately insured just because they operate under different names. In recent years, several banks have used names that differ from the bank's corporate name for branches or the delivery of services over the Internet. The agencies are concerned that, if customers believe they are dealing with two different institutions, they may inadvertently exceed FDIC insurance limits by depositing more than $100,000 in differently named facilities of the same institution.

There are no federal laws or regulations that specifically require that branches or Internet sites of a bank or thrift operate under a single name. The federal agencies issuing the guidance the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Office of Thrift Supervision believe that as a matter of good business practice banks and thrifts should take steps to avoid confusing customers as to the scope and extent of FDIC insurance. The interagency statement, which will become effective on July 1, 1998, contains guidelines on procedures that may be adopted to help avoid such confusion.

For more information, call Sue E. Auerbach, senior attorney, Bank Activities and Structure Division, at (202) 649-6550.

Robert B. Serino
Deputy Chief Counsel

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