We are not aware of any laws that address a reduction in branch hours, 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.

Also note that the cut-off hour for the receipt of deposits may be no earlier than 2:00 p.m. (or 12:00 p.m. for ATMs) under Regulation CC, but you do not have to accept deposits after noon if you close the branch at noon. Comment 6(c), Official Staff Commentary, 12 CFR 229.19(a). Of course, all loan payments must be credited on the date of receipt, with a cut-off hour of no earlier than 5:00 p.m., even if you do not process the payment until the next day. 12 CFR 1026.10.

In addition to complying with the statutory and regulatory requirements, you should review any disclosures and account agreements to see if you have agreed to provide certain notifications about the change in hours. It would be prudent to provide advance notice of the change in hours and to 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 and to contact your regulator, 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 branch 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.