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Someone close to me operates a small business, and has been doing their banking through a relatively young fintech startup which advertises "full-stack business banking". Recently, with only seven business days of advance notice, the "bank" announced that until a to-be-determined time later this year, they would no longer be providing their customers the ability to deposit checks.

To me, this feels like a very fundamental service that I would expect any banking product to offer, which brought me to this question: are there are any minimal services which a company is required to offer to be able to call themselves a bank within the United States?

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Banking regulations in the US are convoluted and spread across Federal/State governments/laws and various different Federal and State regulators. So what specific regulations apply to your specific bank depends on whether or not it is a State or a National bank (or another type of institution, see here), or maybe a Credit Union (which is actually not a bank, by law).

However, generally the laws don't regulate how services should be provide technically. Banks refusing to allow check deposits altogether is an outlier, but banks not allowing remote or mobile deposit, limiting deposit amounts, putting holds on deposits - is not new. Similarly banks may charge fees for something other banks provide for free, etc.

The laws generally regulate things like non-discrimination in services, lending rules, unethical behavior, fiduciary relationships, usury, and of course monetary stability requirements and deposit ratios.

What agency to complain to may also depend on the type of the institution and the State. You can probably start with the CFPB or the FTC, but some States may have powerful consumer protection watchdogs of their own (usually under State's Attorney's General office).

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  • Thanks for this answer! I'm interested in it from a theoretical perspective as much or more so than thinking the answer will give any recourse in this specific situation, so I appreciate you addressing the question in in both senses.
    – Sam Hanley
    May 21 at 18:34

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