For a state-chartered bank, the answer depends on whether the federal holiday is listed as a legal holiday in the Illinois Promissory Note and Bank Holiday Act (the “Act”). Illinois banks are not required to provide advance notice when they plan to remain closed on any day that is designated within the Act as a “legal holiday.”  

If an Illinois state-chartered bank wishes to remain closed on a day other than a legal holiday specified in the Act (or a day that the bank has selected to regularly be closed), the bank must: (1) adopt a resolution authorizing the closure; (2) send a copy of the resolution to the IDFPR; and (3) conspicuously post a notice in the lobby of the main banking office and any branches for at least three weeks before the closure.

Therefore, you should confirm whether the federal holiday on which you wish to remain closed is a “legal holiday.” A list of legal holidays for 2016 is posted on the IDFPR’s website. In addition to this list, legal holidays under the Act also include general election days for members of the House of Representatives and any day the governor may proclaim as a legal holiday.

For nationally chartered banks (which are not subject to the Act), we are not aware of any laws that require advance notice before closing on a federal holiday, although many banks choose to provide notice as a courtesy to their customers.

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 day a bank may, but is not required to, remain closed: . . .”)

• Promissory Note and Bank Holiday Act, 205 ILCS 630/17(c) (“If an occasion arises when a state bank wishes to remain closed on a particular day, other than a day on which the bank has selected to remain closed on a regular basis as provided in this Section, such state bank may remain closed on such an occasion after first sending to the Commissioner a copy of a resolution adopted by the board of directors authorizing the bank to remain closed on such occasion and notice of the intent to remain closed on such occasion shall be conspicuously posted in the lobby of the main banking office and any branches of such bank for at least 3 weeks in advance of such occasion. Any day which any bank doing business within the State shall select to remain closed pursuant to this Section shall, with respect to such bank, be treated and considered as a Sunday.”)