OCC Opinions and Letters on Permissible Electronic Banking Activities: Internet Access

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
CornerBank, NA, Conditional Approval No. 733 (March 2006). National bank may establish a wholly owned operating subsidiary to provide Internet access to its customers and nonbank customers as part of its package of internet banking services.	Conditional Approval No. 733 (PDF)
FSG Bank, NA, Conditional Approval No. 664 (November 16, 2004). National Bank may establish and operate two branch offices that will offer services including access to the internet at in-branch computers, on the condition that the service is a promotional activity, is offered without charge, and controls are put in place to prevent inappropriate access to information, including confidential information of the computer user and bank customers.	Conditional Approval No. 664 (PDF)
National Bank of Commerce, Conditional Approval No. 612 (November 21, 2003). National bank may offer internet access to its customers at branch office sites without charge. This is a permissible promotional activity since it is offered on a non-profit basis. The bank is expected to place appropriate controls on the service to protect the bank and its customers from risks of using publicly available terminals.	Conditional Approval No. 612 (PDF)
Wilbur National Bank, Conditional Approval No. 409 (August 10, 2000). National bank may establish a wholly owned operating subsidiary to provide, incidental to the parent bank's provision of Internet banking services, Internet access to bank customers in the bank's service area.	Conditional Approval No. 409 (PDF)
Integrion, Conditional Approval No. 221 (December 4, 1996). National bank operating subsidiaries may acquire and hold a minority interests in the limited liability company ("LLC") that will supply a network for home banking systems. The LLC will also enable participating financial institutions to offer their customers full Internet access as part of a package of home banking services.	Conditional Approval No. 221 (PDF)
Apollo, Interpretive Letter No. 742 (August 19, 1996). National banks may provide full Internet access service in connection with its Internet banking services and, incidental to that, may sell good faith excess capacity in access service to persons who are not Internet banking customers.	Interpretive Letter No. 742 (PDF)