If we want to close one of our offices on September 13th, what do we need to send to the IDFPR?

The Promissory Note and Bank Holiday Act provides that if a state bank wishes to remain closed on a particular day that is not a holiday or a day on which the bank has previously selected to regularly remain closed, the bank must send the IDFPR a copy of a resolution adopted by the bank’s board of directors authorizing the closure. The bank also must post notice of the closure at the main banking office and any branches at least three weeks in advance of the closing.

Although the Act does not specifically mention branches, we have previously discussed this law with a representative of the IDFPR, who said the agency’s position is that the Act’s requirements apply to branch closings.

For resources related to our guidance, please see:

  • Promissory Note and Bank Holiday Act, 205 ILCS 630/17(c) (“If an occasion arises when a state bank wishes to remain closed on a particular day, other than a day on which the bank has selected to remain closed on a regular basis as provided in this Section, such state bank may remain closed on such an occasion after first sending to the Commissioner a copy of a resolution adopted by the board of directors authorizing the bank to remain closed on such occasion and notice of the intent to remain closed on such occasion shall be conspicuously posted in the lobby of the main banking office and any branches of such bank for at least 3 weeks in advance of such occasion. Any day which any bank doing business within the State shall select to remain closed pursuant to this Section shall, with respect to such bank, be treated and considered as a Sunday.”)