Topic: Bank Signage
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Would any Federal Notices that our bank already has posted (like for example “the Equal Employment Opportunity is The Law” federal notice) meet the requirements of the Illinois Human Rights Act? Or should the Illinois Human Rights Act notice be posted in addition to other federal notices? We are a national bank regulated by the OCC.
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Yes, we believe your bank is required to post the Illinois Human Rights Act notice, in addition to the required federal notices. We are not aware of any federal banking or employment laws that would preempt notice or disclosure requirements in state employment laws for national banks. Nor do we think this particular notice requirement…
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Do the beneficial ownership requirements in the new customer due diligence final rule that takes effect May 11, 2018, include any new signage requirements for banks? Our forms vendor called to promote signs that describe the rule’s requirements, but we were not aware that we needed new signs.
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No, the final customer due diligence rule that takes effect on May 11, 2018, does not include new signage requirements for banks, and it does not revise the existing customer identification program (CIP) signage requirements. Whether you wish to purchase and post signs regarding the new beneficial ownership requirements is a business decision for your…
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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…
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We have reported Home Mortgage Disclosure Act (HMDA) data in the past, but we now qualify for an exemption from HMDA reporting due to our low loan volume. Because we are no longer a HMDA reporter, are we required to display or make available any HMDA notices? If so, are we required to include the CFPB’s suggested verbiage in our HMDA lobby notices?
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Yes, we recommend that your bank continue to display and make HMDA notices available, as described below. We contacted the CFPB to clarify the signage responsibilities for a bank like yours (one that reported HMDA data in the past but is not currently a HMDA reporter). The CFPB representative’s informal guidance to us was…
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We are a state member bank regulated by the Federal Reserve Board (FRB). Are we required to post the Annual Disclosure Statement Notice in our lobby? Or does that requirement apply only to FDIC and OCC regulated banks?
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No, your bank is not required to post an Annual Disclosure Statement Notice. The FRB eliminated the requirement to notify the public about the availability of call reports in 1998, when the reports started being available online. The OCC also eliminated its notice requirement, effective April 1, 2017. Banks regulated by the FDIC, however, still…
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Are we required to display a sign stating “ANY INQUIRERS HAVE THE RIGHT TO FILL OUT AN APPLICATION AND TO RECEIVE A COPY OF THE INSTITUTIONS UNDERWRITING STANDARDS”?
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The regulations for federal savings associations require your institution to “inform each inquirer of his or her right to file a written loan application, and to receive a copy of the association’s underwriting standards.” However, we do not believe this information needs to be displayed on a sign at your institution. Back in 1979, the Federal Home…
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We are opening a new branch and have limited room on the outdoor sign that will identify the branch. On the sign, can we shorten our bank name by removing one word – using “XYZ Bank” instead of our full name, which is “XYZ Community Bank”?
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Yes, we believe that you may display a shortened (but still identifiable) version of your bank name on an outdoor sign. In our view, omitting the word “Community” from the bank name should not create customer confusion. State and federal guidances require reasonable steps to avoid customer confusion when a bank uses a name other…
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Does Illinois have any special signage requirements for in-state branches owned by an out-of-state bank? We found some requirements for insurance products and for holiday closings, but we want to make sure we’re not missing anything else.
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We are not aware of any special signage requirements for branches of out-of-state banks in Illinois. As you noted, the Illinois Promissory Note and Bank Holiday Act requires a public notice when a bank will be closing on a day other than days when the bank is closed on a regular basis. Also, the Illinois…
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What kind of notice or signs should we provide if we will not be accepting cash deposits in our newest branch?
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We are not aware of any Illinois or federal laws that require signage or notices to customers that a branch does not accept cash deposits. However, for customer service purposes, it may be prudent to post signs at any deposit taking areas (such as teller windows and ATMs) to warn customers about the policy. We…
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What are the OSHA responsibilities for banks? Are there any forms we should be completing or posters we should be displaying? How about filing injury reports to OSHA?
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All employers, including banks, are required to display an OSHA poster at every branch and other office location. Since financial institutions are “partially exempt” from the OSHA reporting requirements, your bank is not required to submit regular reports to OSHA on workplace injuries. However, while financial institutions are partially exempt, they must report fatalities, in-patient…