Circular
Interagency Policy Statement On Branch Names
July 17, 1998
Circular No. 11074

To All Bank Holding Companies and State Member Banks in the Second Federal Reserve District:

The Board of Governors of the Federal Reserve System and the other federal banking agencies recently issued an interagency policy statement concerning the practice of insured depository institutions operating branches of the same institution under different trade names. The agencies are concerned that if depositors believe that such facilities are operated by separate institutions, they may inadvertently exceed FDIC insurance limits by depositing excess amounts in accounts in different branches of the same institution. The agencies believe it is important that customers understand fully the scope of FDIC deposit insurance coverage in these circumstances.

The interagency policy statement emphasizes that an insured depository institution that intends to use different names for various branches or other facilities of the same institution should take reasonable steps to ensure that customers will not become confused and believe that its facilities or branches are separate institutions, or that deposits in different facilities are separately insured. The policy statement describes various steps that should be taken to avoid confusion regarding federal deposit insurance coverage.

In the event you have any questions concerning this matter, please contact Janice A. Oser, Examing Officer, at this Reserve Bank.