Yes, because this branch will remain closed for a full day every Saturday, we believe that your bank must follow the notification procedures in the Illinois Promissory Note and Bank Holiday Act (the “Act”) for regular bank closings.

Under the Act, Saturdays are considered half holidays, and banks are permitted to remain closed after noon on Saturdays without taking further steps. However, if a branch will remain closed all day on Saturdays on a regular basis, the Act requires the bank to take the four steps required for regular branch closings: (1) adopting a board resolution authorizing the closure, (2) recording an officer-certified copy of the resolution, (3) publishing the resolution in a county-wide newspaper once each week for three successive weeks before the closure, and (4) submitting evidence of the newspaper publication to the IDFPR.

Note that the Act applies to a “bank” remaining closed but does not mention the individual branches of a bank. Based on conversations we have had with the IDFPR, it is the agency’s position that the Act’s notification requirements apply to branch closings. Accordingly, if you wish to close a branch regularly for a full day other than Sunday, your bank should follow the four steps outlined above.

We also note that closing a branch for an additional day each week has potential implications under the Community Reinvestment Act. One factor in your bank’s service performance rating is whether your services, “including, where appropriate, business hours,” vary in a way that inconveniences customers in your assessment area. Therefore, it may be prudent to document your business reasons for closing this branch on Saturdays, although you are not required to do so.

For resources related to our guidance, please see:

• Promissory Note and Bank Holiday Act, 205 ILCS 630/17(a) (“The following days shall be legal holidays in the State of Illinois upon which a bank, but is not required to, remain closed: . . . . From 12 o’clock noon to 12 o’clock midnight of each Saturday shall be considered a half holiday.”)

• Promissory Note and Bank Holiday Act, 205 ILCS 630/17(b) (“Any bank doing business within this State may select any one day of the week to remain closed on a regular basis upon adoption of a resolution by the board of directors of such bank designating the day selected and upon filing and publishing a copy of such resolution as hereinafter required. Any such resolution shall be deemed effective for the purpose of this Section only when a copy thereof, certified by an officer having charge of the records of such bank, is filed with the Recorder of the county in which such bank is located and published once each week for 3 successive weeks in a newspaper of general circulation in such county. Such publication shall be accomplished by, and at the expense of, the bank, and the bank shall submit to the Commissioner of Banks and Real Estate such evidence of the publication as the Commissioner shall deem appropriate. Any such selection shall remain in full force and effect until a copy of the later resolution of the board of directors of such bank, certified in like manner, terminating or altering any such prior selection shall be filed and published in the same manner as such prior resolution.”)

• 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 . . .”)