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We were recently acquired by a bank in Iowa. We want to decrease our drive-through and walk-up hours, but increase our lobby hours. We plan on posting advance notice of the change in our lobby. How many days’ notice should we provide? We asked the OCC, but we were informed to check state law. – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We were recently acquired by a bank in Iowa. We want to decrease our drive-through and walk-up hours, but increase our lobby hours. We plan on posting advance notice of the change in our lobby. How many days’ notice should we provide? We asked the OCC, but we were informed to check state law.

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We are not aware of any laws that expressly address a change in bank hours, including the amount of customer notice to provide. We recommend that you check your account agreements to see if they include any relevant notification requirements. You also should consider updating relevant advertising, listings and other information to reflect the new hours (as well as any disclosures and account agreements that reflect the previous hours).

We also note 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. Therefore, it would be prudent to document your reasoning for making the change, though you are not required to do so.

For resources related to our guidance, please see:

  • Community Reinvestment Act, Appendix A to Part 25 – Ratings, Part (b)(3) (“The OCC rates a bank’s service performance ‘outstanding’ if, in general, the bank demonstrates: . . . Its services (including, where appropriate, business hours) do not vary in a way that inconveniences its assessment area(s), particularly low- and moderate-income geographies and low- and moderate-income individuals . . .”)