Regulatory Alerts1999-06-30
Pennsylvania Department of Banking Clarification on Human Resource Consulting Services
The Pennsylvania Department of Banking clarifies that the Pennsylvania State Bank may offer human resource consulting services through its subsidiary, subject to a minor safety and soundness risk standard rather than a strict 10% cost threshold. The Department aligns its position with the Office of the Comptroller of the Currency by permitting these services only if performed by personnel hired primarily for internal bank purposes who utilize excess time capacity. This approval modifies the Department's prior May 25, 1999 letter and requires compliance with OCC guidelines and potential FDIC approval for any activities exceeding national bank subsidiary authority.
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