We are not aware of any laws that address a reduction in hours for a drive-up facility, and we can only make suggestions as to reputation risk and CRA risks. The Illinois Promissory Note and Bank Holiday Act imposes duties when a bank plans to close a branch on a particular day each week, but it is silent as to a reduction in hours. 205 ILCS 630/17.

We do recommend checking any agreements or signature cards to ensure that they do not contain any notification requirements. It may be prudent to provide advance notice of the change in hours to your customers and your primary regulators. Update any advertising, listings, and information about the branch to reflect the new hours, as well as disclosures and account agreements (which changes may require notice to customers).

The change in hours may raise some Community Reinvestment Act (CRA) concerns. One factor in your service performance rating is whether a branch’s services, “including, where appropriate, business hours,” vary in a way that inconveniences customers in your assessment area. See Appendix A to Part 228—Ratings, Part (b)(3). Therefore, it would be prudent to document your reasoning for making the change, though you are not required to do so. As part of your documentation process, you may want to include some of the following information, adapted from the Metavante policy on branch closings:

• The bank’s efforts to keep the branch profitable during the hours that are being reduced;
• The drive-up hours of other financial institutions in the branch’s neighborhood;
• Any actions taken to notify the public and your customers of the change in hours, with copies of any notifications; and
• Any actions taken to minimize the impact of the change in hours.