No, we are not aware of any Illinois law or regulation that requires notice of a reduction in your drive-up banking hours. However, we recommend checking your account agreements to ensure they do not include relevant notification requirements.

We also recommend posting advance notice of the changed hours in your Illinois branch lobbies and on your website as a courtesy to your customers, as well as notifying your primary regulator. You also should update relevant advertising, listings, and other information to reflect the new hours (as well as any disclosures and account agreements that reflect the previous hours).     

Additionally, we note that a change in hours can in some instances raise issues under the federal Community Reinvestment Act (CRA). One factor in your bank’s CRA service performance rating is whether your services, “including, where appropriate, business hours,” vary in a way that inconveniences customers in your bank’s 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:

• Promissory Note and Bank Holiday Act (Does not address a bank’s decision to reduce its hours.)
   
• 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 . . .”)