Advisory Letter 2025-02 Reduction in Regulatory Burden for Certain Branch Activities

Depository Division Advisory Letter 2025-02 August 15, 2025

To: All State-Chartered Financial Institutions From: Christopher C. Dietz, Deputy Director – Depository Institutions Re: Reduction in Regulatory Burden for Certain Branch Activity Approvals

The Department continues to identify ways to reduce regulatory burden and create efficiency for our financial institutions. In such an effort, the agency is streamlining specific approval processes for new (denovo) branch requests, certain purchase and assumptions of a branch(s), and branch relocations.

Beginning September 1, 2025, in accordance with the Indiana Department of Financial Institutions Policy Establishing Expedited Branch Procedures, financial institutions that explicitly state in their branch activity letter to the Department how they meet the expedited approval requirements outlined within the Department Policy shall consider their branch request approved if they do not receive any Department requests for additional information or instructions to pause the branch application process within 15 business days of the Department’s letter acknowledging receipt of the financial institution’s branch request. This expedited process is designed to create efficiencies for our financial institutions when filing a request with the Department, eliminating the need to fill out a formal application and then subsequently wait for approval correspondence back from the Department.

If a financial institution does not meet all seven (7) criteria outlined in the Policy, the financial institution must continue to file the formal branch activity application, and the Department’s review and approval will remain in line with the long-standing statutory process.

We do have an ask of you. To streamline the process and reduce Department requests for additional information, when requesting a denovo branch or branch relocation approval, the Department asks that the financial institution submit a letter request as detailed in the Policy, and ensure the letter includes the specific information on the cost of the branch, the location of the branch, if the branch is financial institution owned or leased, and specific information on how the financial institution meets each of the seven (7) criteria outlined. For example, as requested in Policy Criteria two: (2) state the Tier 1 Leverage Capital or Net Worth ratio projected for the quarter immediately after the branch activity is consummated, not just a statement indicating that the capital ratio will exceed the criteria.

This expedited process applies only to eligible financial institutions requesting a denovo branch, relocating a branch, or the purchase and assumption of a branch. The Department may pursue future legislation to expand this process to principal office relocation and trust office relocation, and we will revise the Policy accordingly if the legislative changes are enacted.

If you have any additional questions on this process, feel free to reach out.