We are not aware of any Illinois or federal law that requires you to notify customers when altering branch hours. However, we recommend checking your account agreements to ensure they do not include relevant notification requirements. We also recommend posting advance notice of the changed hours in the lobby of any affected branch and on your website as a courtesy to your customers, as well as notifying your primary regulator. You also should update relevant advertising, listings, and other information to reflect the new hours (as well as any disclosures and account agreements that reflect the previous hours).    

Additionally, we note that a change in hours can in some instances raise issues under the federal Community Reinvestment Act (CRA). One factor in a large bank’s CRA service performance rating is whether its services, “including, where appropriate, business hours,” vary in a way that inconveniences customers in the bank’s assessment area. Consequently, it would be prudent to document your reasons for changing a branch’s hours, although you are not required to do so.

For resources related to our guidance, please see:

• Community Reinvestment Act, Appendix A to Part 345 – Ratings, Part (b)(3) (“The FDIC rates a bank’s service performance ‘outstanding’ if, in general, the bank demonstrates: . . . Its services (including, where appropriate, business hours) are tailored to the convenience and needs of its assessment area(s), particularly low- or moderate-income geographies or low- or moderate-income individuals . . .”)