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Banking Interpretations

November 13, 2001 

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Re: Deposit Related Activities

Dear [          ]:

This letter is in response to your letter of November 8, 2001 seeking further clarification of my opinion of November 1, 2001, a copy of which I have attached hereto for your convenience.  In particular you request clarification with regard to the requirement that the bank's customer and the courier enter into a written agreement whereby the courier must be the agent of the bank's customer.  In your letter you point out that the Office of the Comptroller of the Currency does not prohibit a national bank from contracting directly with the third party courier to pick up deposits from customer locations and delivering them to a third party service bureau, correspondent bank, or other permissible facility such as a back office facility.

The Banking Department in an opinion dated January 11, 1996 stated that it would not object if a bank, instead of its customer, enters into the contract with a courier service.  I have attached a copy of the opinion for your consideration.

I apologize for any confusion my earlier opinion may have caused you. Should you have any additional questions please feel free to contact me at[                       ].

Sincerely yours,

Jay Kane
Assistant Counsel

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