We have decided to reduce our bank’s lobby hours. Are there any notification requirements in Illinois that are required prior to this change?

No, we are not aware of any laws that expressly address a reduction in branch hours. We do recommend that you check 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 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 should note that the change in hours can in some instances raise issues under the Community Reinvestment Act. One factor in your service performance rating is whether your offices' services, “including, where appropriate, business hours,” vary in a way that inconveniences customers in your 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:

  • 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 . . .”)