IBA Compliance Connection

Your go to source for compliance!

We are planning to close all of our Christmas Club accounts. The accounts do not have check writing or other transaction privileges — we simply issue checks for the account balances once per year, in October. Our account agreements state that we may close an account any time with “reasonable notice.” We plan to include notice of the closing, effective immediately, when we issue checks this October. Is that sufficient notice of closing?

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We recommend providing some advance notice before mailing the checks and closing the accounts in October. While nothing in Illinois or federal law appears to require advance notice of closing these accounts, your account agreements do require “reasonable notice.” In our view, reasonable notice should be provided in advance of the account closing. In addition, providing notice that is effective immediately may be viewed as poor customer service.