No, we do not believe you are required to notify your customers that your drive-through windows will be closed for one day or obtain permission for the closure from the OCC. However, we believe it would be a best practice to notify your customers and the OCC of the temporary closure.

The Branch Closings booklet of the Comptroller’s Licensing Manual provides that a “bank is not required to notify the OCC of a closing caused by a temporary interruption of service, but it would normally be sound practice to do so.” The Branch Closings booklet also indicates that a bank may reduce certain functions or services at a branch “without being subject to the branch closing requirements” but notes that “giving customers appropriate advance notice of service changes [is] a good business practice even when statutory branch closing requirements are not applicable.”

Consequently, we recommend notifying the OCC that your drive-through windows will be closed for one day and posting advance notice of the temporary closure in a conspicuous manner at the affected branch.

For resources related to our guidance, please see:

• Comptroller’s Licensing Manual, Branch Closings, page 5 (February 2023) (“A bank is not required to notify the OCC of a closing caused by a temporary interruption of service, but it would normally be sound practice to do so.”)

• Comptroller’s Licensing Manual, Branch Closings, page 5 (February 2023) (“A bank may alter the operations conducted at a branch without being subject to the branch closing requirements if the facility remains a branch. For example, the branch’s hours of operation may be reduced, or certain functions or services previously provided at that location may be eliminated. Nevertheless, a bank should consider giving customers appropriate advance notice of service changes as a good business practice even when statutory branch closing requirements are not applicable.”)