OCC Opinions and Letters on Permissible Electronic Banking Activities: Data Processing

OCC publishes letters associated with charter approvals and other licensing activities, including interpretive letters. Some of these letters provide interpretations of existing laws and regulations. This section includes significant approval letters and interpretations associated with Internet banking activities. The following is a listing of topics in this section that also serve as quick links to the referenced materials:

Description	Opinions & Letters
La Salle Bank, NA, Corporate Decision No. 2006-05 (July 2006). National bank may acquire an operating subsidiary that will offer services to manage healthcare receivables, providing customers with scanned electronic images of benefits explanations, creating electronic files, and creating a web based portal whereby customers can index and sort information, and may in the future provide collection services to these customers.	Corporate Decision No. 2006-05 (PDF)
Interpretive Letter No. 993 (June 2004) Activities including data and payments processing of a Clearing House are part of or incidental to the business of banking, and thus it is permissible for a national bank to own an interest in such a clearing house.	Interpretive Letter No. 993 (PDF)
Extraco Bank, N.A.,Corporate Decision #2002-11 (June 28, 2002). A national bank's operating subsidiary may provide advisory and consulting services to the bank's customers who use the bank's electronic retail or wholesale transactional services; the advice can cover the hardware, software, and other technologies necessary to use those services. The subsidiary may also provide advisory and consulting services to business customers on the hardware, software, and other technology necessary to enable those customers to process for themselves banking, economic, and financial information.	Corporate Decision No. 2002-11 (PDF) Interpretive Letter No. 986 (PDF)
Chase I-Vault, Interpretive Letter No. 888 (March 14, 2000). A national bank may, as part of the business of banking, provide electronic image processing services involving the loading, storage, and retrieval of banking, financial, and economic data and documents.	Interpretive Letter No. 888 (PDF)
Anexsys, Conditional Approval No. 361 (March 3, 2000). As part of the business of banking, national banks can process banking, financial, or related economic data. This includes processing input data that is not itself "banking, financial, or economic data" if the processing seeks banking, financial, or economic correlations or relationships within the non-banking data or otherwise derives or produces information which is banking, financial, or economic in nature.	Conditional Approval No. 361 (PDF)
Southwest Bank, N.A., Interpretive Letter No. 928 (December 24, 2001). A national bank may process for its merchant customers retail based information relating to the identity, shipping information, and payment information with respect to the merchants' end customers because it involves the processing of banking, financial, and economic data.	Interpretive Letter No. 928 (PDF)