Banking Interpretations


Rosanne Notaro


Subject: Section 337 - Safe Deposit Boxes [—]

Dear Mr. [—]:

I apologize for the delay in getting back to you on your question. The Department will not require an application pursuant to BL 337 for the sale of safe deposit boxes outside of New York.  We would ask that [—] advise the Department of any requirements concerning the sale of safe deposit boxes under Texas law, or, if there are none, what [—] might plan to do voluntarily in terms of notifying the safe deposit box customers.  This information would be helpful for the Department to have in its files.

Please let Steve or me know if you have additional questions.

Best regards,

Rosanne Notaro
Deputy Counsel



To Rosanne Notaro

Ms. Rosanne Notaro

I am in-house counsel for [—].  I advised Steven Kupfer of NYSBD that [—] has announced that it will sell six (6) of its bank branches that are located in the Houston, Texas region. One of those six Texas branches maintains safe deposit boxes. Mr. Kupfer asked me to write to you regarding the need for [—] to file a Section 337 application for “sale of safe deposit business."

Could you please advise me whether [—] will need to file such Section 337 application? The question is whether [—] needs to file a formal application for sale of safe deposit boxes that are located outside of New York and are maintained in the Houston, Texas region?