Depository Notice: Sharing Branch Space During an Emergency


Dear State-Chartered Depository Institution Managers;

We have received several inquiries about the sharing of branch space between different depository institutions.  We appreciate those who are offering to help their neighbors in this disaster situation when they might otherwise be competitors in normal times.  These arrangements may have many challenges, such as staff availability and third-party servicer capability.  Some have asked about regulatory considerations, as well.

We want to help alleviate any regulatory concern by pointing out that the Emergency Declaration that I issued on Friday, August 27, 2021, specifically permits a state-chartered financial institution in the affected area to close any facility and to open any temporary facility with after-the-fact notice to the Office of Financial Institutions (OFI).  Temporary facilities may be opened anywhere that is appropriate to serve customers, including within a facility that is also a main office or branch of a different financial institution.  Therefore, no additional authority is required from OFI for state chartered depository institutions to engage in the sharing of branch space.  We ask simply that you notify OFI and your primary federal regulator in accordance with normal emergency procedures regarding temporary facilities.

If you require assistance in providing services to your customers/members, we encourage you to reach out to your neighboring depository institutions and/or your trade association.  To the extent OFI can be of assistance, please contact Chief Examiner Jonathan Finley at jfinley@ofi.la.gov or (225) 362-1385.

Sincerely,

Stanley M. Dameron, Commissioner

Louisiana Office of Financial Institutions