Topic: Bank Signage
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Do we need to post the FDIC official sign on our night deposit boxes that are on the outside wall of our branches?
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No, you are not required to post the official FDIC sign on night deposit boxes. An FDIC Advisory Opinion states: “FDIC regulations do not specifically reference night depositories, but FDIC staff has generally taken the view that deposits are not ‘received’ by the bank when the deposits are placed in a night depository; hence, no…
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Are we required to display the Annual Disclosure Statement, HMDA Disclosure Notice, CRA Notice and Equal Housing Poster at a branch that has only a drive-up facility? The facility is approved as a branch, and there is one teller onsite.
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Annual Disclosure Statement: Yes. You are required to post the Annual Disclosure statement at each branch. HMDA Data Availability Notice: Maybe. If the drive-up is approved as a branch by a federal or state agency and is located in a Metropolitan Statistical Area or a Metropolitan Division, then you are required to post the HMDA…
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At our corporate headquarters, which is not our main office, we accept loan applications (commercial and/or consumer) and loan payments, and we also perform loan modifications. What types of signage are required at the corporate headquarters?
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There are signage requirements in both Illinois and federal laws, and whether these signs or notices are required depends on the activities performed at your corporate headquarters. In addition, some of these requirements apply only if the corporate headquarters is your “main office” or a “branch.” While you have told us that the corporate headquarters…
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Are there federal and/or state laws requiring that the bank notify the public in advance if the bank is going to be closed for a federal holiday (i.e. 4th of July)?
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We are not aware of any state or federal laws that would require advance notice of a bank closing on the Fourth of July, though many banks choose to provide notice of holiday closings as a courtesy to their customers. Illinois banks are permitted to remain closed as follows: (1) on any holiday listed in…
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Does the Illinois Human Rights Act require any notices to be displayed in banks?
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Effective January 1, 2015, the Illinois Human Rights Act requires the Illinois Department of Human Rights to prepare and approve a notice with “information concerning an employee’s rights,” which must be either “posted in a conspicuous location on the premises of the employer where notices to employees are customarily posted” or included in any employee…
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Do you have a list of the employment law posters that we need to display in Illinois?
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Below is a list of Illinois laws that may require you to post a notice or poster. Unless otherwise noted, most posters are available for download on the Illinois Department of Labor’s website, which also has links to other Illinois departments’ required postings. That website also has some of the federally-required postings (though it has…
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Since we are changing from a national charter to an Illinois charter, are there any signage requirements unique to Illinois that we should know about?
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Generally, Illinois laws and regulations do not have any requirements or prohibitions as to bank signage, although the Illinois Banking Act has a general rule against unsafe and unsound practices that prohibits banks from using confusing, deceptive, or misleading bank signs. 205 ILCS 5/48(8). Also, various Illinois laws may require some additional signs, such as…
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What lobby disclosures are required for a state bank for an LPO (loan production office) if we do no retail or deposit business at the LPO?
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Unfortunately, there is no clear guidance on the public notices required at loan production offices (though there is some guidance on the notices required at branches). With that in mind, here are our thoughts: 1. Illinois Employment Notices: Your LPO, as with all of your organization’s Illinois offices, may need to post the following employment…