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We are considering closing a couple of our branches for one afternoon a week. Are there any rules that would apply to a bank reducing its hours? We are running the change by our CRA officer. – IBA Compliance Connection

We are considering closing a couple of our branches for one afternoon a week. Are there any rules that would apply to a bank reducing its hours? We are running the change by our CRA officer.

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No, we are not aware of any laws or regulations that expressly address a reduction in branch hours. We do recommend checking your account agreements to ensure that they do not include relevant notification requirements.

We also recommend posting advance notice of the changed hours in your main bank and branch lobbies, 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).

You noted that your CRA officer will be reviewing this change; we believe that this review is appropriate because a change in hours can in some instances raise issues under the Community Reinvestment Act. One factor in your bank’s CRA service performance rating is whether your services, “including, where appropriate, business hours,” vary in a way that inconveniences customers in your bank’s assessment area. Consequently, it would be prudent to document your reasons for making the change, although you are not required to do so.

For resources related to our guidance, please see:

  • Promissory Note and Bank Holiday Act (Does not address a bank’s decision to reduce its hours.)

  • 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) do not vary in a way that inconveniences its assessment area(s), particularly low- and moderate-income geographies and low- and moderate-income individuals . . .”)