TO THE CHIEF EXECUTIVE OFFICER OF THE STATE CHARTERED BANK ADDRESSED:
Re: Courier ServiceIt has been brought to our attention that some banks are providing deposit courier service for a number of their customers. This practice constitutes impermissible "branch banking" and violates Iowa Code Section 524.1201 (1989). Quite obviously, it is not permissible for a bank to provide courier service directly with its own employees. We believe the only involvement a commercial bank may have in providing this type of service is where the bank arranges for a third party courier service to stop at the place of business of a bank customer. The entire cost of the service must be borne by the customer with the bank providing no subsidy whatsoever for such service.
If your bank is providing deposit courier service in violation of Iowa Code Section 524.1201 (1989), we ask that you discontinue the service immediately. If your institution is only providing the service through the arrangement mechanism of a third party courier service, this would seem to be legal, providing the customer pays the actual cost of the service. Billing the bank customer for the service must be done directly by the courier. There can be no subsidy on fees by the bank. We hope all concerned banks will resolve the issue without further involvement of this office. Many thanks in advance for your cooperation.Most sincerely,
Robert R. Rigler
Superintendent