We do not believe that any Illinois or federal laws would impose a notice requirement during times when no tellers are available to transact business.

Regulation CC would not impose any notice requirements, as it explicitly does not “require a depositary bank to open or otherwise to make its facilities available for customer transactions on a given business day.” 12 CFR 229.19(c)(3). As explained in the staff commentary, this means that the regulation does not require “a depositary bank to have facilities open for customers to make withdrawals at specified times or on specified days.” Official Interpretations, 12 CFR 229, Paragraph (c), Comment 3. If your facilities are temporarily closed due to a teller’s break, we do not believe that Regulation CC requires you to stay open. In addition, the Illinois Promissory Note and Bank Holiday Act does not impose any notice requirements — it does not apply to temporary periods during which teller services are unavailable, as it applies only when a bank proposes to close a branch for an entire day. 205 ILCS 630/17.

We do agree that it would be a best practice to post a sign whenever your deposit services are unavailable due to a temporary teller break.