Topic: Bank Signage
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Are banks required to put baby changing tables in their gender-neutral restrooms?
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No, we do not believe that banks are required to put baby changing tables in their gender-neutral restrooms. Although the Equitable Restrooms Act (ERA) requires that “public building[s] with restrooms open and accessible to the public” have at least one baby diaper changing station in both the women’s restroom and the men’s restroom, or in…
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According to Illinois’s recently-amended Equitable Restrooms Act (ERA), a “single-occupancy restroom” contains “no more than one urinal.” Does this mean a single-occupancy restroom must contain at least one urinal? Also, would a sign on a single-occupancy restroom stating “Restroom” comply with the law, or must it state “All Gender Restroom”?
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No, a single-occupancy restroom is not required to have a urinal. The ERA defines a single-occupancy restroom as a room containing one toilet stall and no more than one urinal, but it does not impose a requirement to include a urinal. A single-occupancy restroom must be identified as an “all-gender” restroom to comply with the…
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Our understanding of the new Illinois law regarding signage on single-occupancy public restrooms is that it applies to banks and requires each such restroom to be labeled as an “All Gender Restroom” without any characters on the sign. Please clarify what language is required on these signs. Also, if we have one restroom that is designated for customer use and one that is designated for employee use (that reads, “employees” on the door), do we need to change the signage for these restrooms?
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You are correct that a recent amendment to Illinois’ Equitable Restrooms Act (ERA) regarding “all-gender” restroom signage applies to banks, which are included in the law’s definition of a “place of public accommodation.” Additionally, your bank is required to designate all of your single-occupancy restrooms as “all-gender” restrooms, regardless of whether they are intended for…
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Regarding the new Illinois law regarding signage on single-occupancy public restrooms, if we currently have two single-occupancy restrooms with signage designating one restroom for men and one restroom for women, do we still have to label the single-occupancy restrooms as “all-gender”?
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Yes, we believe your bank must designate its single-occupancy restrooms as “all-gender” rather than designating one for men and one for women. Illinois’ recently amended Equitable Restrooms Act (ERA) requires that “every single-occupancy restroom in a place of public accommodation or public building shall be identified as all-gender” and “outfitted with exterior signage that marks…
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Are banks subject to the new Illinois law regarding signage for single-occupancy public restrooms? We do not designate our restrooms as “public,” but we do allow the public to use them on request, including non-customers. These restrooms are contemplated to be used by employees only and are not located near our public entrances.
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Yes, banks are subject to a recent amendment to the Equitable Restrooms Act requiring that “every single-occupancy restroom in a place of public accommodation or public building shall be identified as all-gender” and “outfitted with exterior signage that marks the single-occupancy restroom as a restroom and does not indicate any specific gender.” The Equitable Restrooms…
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We have received questions about allowing customers to take pictures in our bank lobby or record in-person interactions with bank staff. We would like to prohibit these activities to protect other customers’ privacy and protect sensitive information from disclosure. Should we post signs stating that such activity is prohibited? How do other banks handle this, and what are the best practices?
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Yes, we recommend posting signs if your bank adopts a policy prohibiting unauthorized photography and video recording on bank premises so that your customers and guests are put on notice of this policy. Your bank also may wish to train frontline staff on how to respond when customers take unauthorized photos or video. The American…
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Is our bank required to provide takeaway notices along with our posted HMDA Data Availability Notice? We currently provide takeaway notices in paper form in a slot next to our posted notice.
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No, there is no requirement to provide takeaway versions of the two HMDA notices to all of your customers, provided that your bank has procedures in place to furnish a copy of the required notices to customers who request them. Regulation C requires your bank to provide two HMDA notices to members of the public…
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Are there any size requirements for the following lobby notices: CRA Notice, Annual Financial Disclosure Notice, Equal Housing Poster, HMDA Data Availability Notice, and Regulation CC Funds Availability Notice? Can these notices be displayed on an electronic board that switches between the notices? What does the term “prominently displayed” mean with respect to the Equal Housing Poster? Also, can you confirm that we are not required to disclose our rates on a rate board in our lobby?
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There are size requirements for some (but not all) of the notices listed in your questions. If there are no express size requirements, generally these notices should be sized and placed so that customers are able to see the notices and easily read their text. Each notice is addressed separately below. CRA Notice: The size…
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We are considering reducing the staff at one of our branches from two employees to one on Saturday mornings. However, our procedures require dual control for opening our night deposit box. With only one employee present on Saturday mornings, we would not process deposits placed in the night deposit box on Friday night, Saturday, or Sunday until Monday morning. This would not affect the business day of posting but could affect the funds available to customers over the weekend. Are there any federal or state regulations we should be aware of related to this change? Would it be acceptable to place a sign on the night deposit box stating that transactions deposited Friday night through Sunday will not be processed until the following Monday?
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We are not aware of any federal or state regulations applicable to delaying the processing of deposits placed in a night depository. Posting notice on a night depository of the date when deposits will be processed also is not required by federal or state law. However, we do recommend posting such a notice as a…
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We are integrating new branches as part of a recent acquisition. We will be changing service hours at these branches – in some cases, we are extending the service hours by an hour, and other cases we will be shortening the service hours by one hour. We also may close early one day for a ribbon cutting ceremony. Our current procedures for changes in hours are to provide thirty days advance notice, with conspicuous signage posted in the affected branches. Is any other notice required under Illinois law, such as the Illinois Promissory Note and Bank Holiday Act?
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We are not aware of any Illinois laws that expressly address a change in bank hours, although we agree that it would be prudent to post advance notice of the changed hours. Your bank also may wish to review relevant advertising, listings and other information to ensure that they reflect the new hours (as well…