IBA Compliance Connection

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We were told that a bank was written up by a regulator for not having a sign on its night drop indicating when deposits will be posted. Is there any federal or Illinois law that require such signage at a night drop?

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No, neither Illinois nor federal law requires your bank to have a sign at your night drop depository regarding payment posting.

Regulation CC does require banks to conspicuously post a notice setting forth the time periods for the availability of funds deposited in a consumer account — but only at places where bank employees receive deposits. Regulation CC’s official comments clarify that this notice is not required to be posted at night depository locations.

For resources related to our guidance, please see:

  • Regulation CC, 12 CFR 229.18(b) (“Locations where employees accept consumer deposits. A bank shall post in a conspicuous place in each location where its employees receive deposits to consumer accounts a notice that sets forth the time periods applicable to the availability of funds deposited in a consumer account.”)
  • Regulation CC, Official Interpretations, Paragraph 18(b), Comment 1 (“The notice is not required at any drive-through teller windows nor is it required at night depository locations, or at locations where consumer deposits are not accepted.”)