Regulatory Alerts1994-01-01
Use of Third Party Messenger Services Between Banks and Their Customers
The Kansas Office of the State Bank Commissioner issued this memo to clarify whether third-party messenger services constitute branch banking for state-chartered banks. It permits banks to use third-party couriers for both branching and non-branching activities provided the service meets specific safe harbor criteria such as independent ownership and public availability. Banks are prohibited from establishing their own messenger services for branching activities without commissioner approval, though they may subsidize customer transport costs under defined conditions.
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