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We would like to extend the drive-through hours at one of our branches. The new hours would not affect our cutoff times. Do we have to notify our customers or the OCC, our primary regulator? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We would like to extend the drive-through hours at one of our branches. The new hours would not affect our cutoff times. Do we have to notify our customers or the OCC, our primary regulator?

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No, we are not aware of any laws or regulations that impose notice requirements for increasing drive-through hours. We recommend that you check your account agreements to see if they include any relevant customer notification requirements. You also may 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).