Topic: Branch Closing
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We are having some construction work done at our bank that will require us to close our drive-through windows for one day. Do we need to notify our customers or receive permission for the closure from our primary regulator, the OCC?
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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…
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If a bank chooses to remain open on a federal holiday, would its FDIC insurance coverage lapse on that day? Would there be any concerns if our bank chooses not to close for the Juneteenth holiday, since it will fall on a weekend day for 2022?
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No, FDIC insurance coverage does not lapse when an insured bank chooses to remain open on a federal holiday. We also do not believe there any concerns associated with choosing to remain open on the Juneteenth federal holiday (which the Federal Reserve System recognizes on Monday, June 20 for 2022, since June 19 falls on…
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We are considering closing one of our bank’s branches all day on Thursdays and Saturdays every week. Is this allowed under the Promissory Note and Bank Holiday Act, or are we only able to close on one day that is normally a business day?
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No, we do not believe you are permitted to close a branch on a normal business day and all-day on Saturday every week under the Promissory Note and Bank Holiday Act. Our understanding is that the Act requires banks to remain open at least four and a half days each week. According to the Illinois…
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We are in the process of closing one of our branches and are working with safe deposit box customers to move their items. We haven’t been able to reach approximately thirty customers about their boxes. These customers are current on their payments, but they have not responded to our letters or phone calls. How can we move those boxes?
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We recommend reviewing your lease agreements for the safe deposit boxes and notifying your customers as required in those agreements. We are unaware of any law that directly addresses drilling a safe deposit box when the lessee is alive and is current on lease payments, which would be the case here. Whether and when you…
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We are an FDIC-supervised savings bank and are considering closing one of our branch offices. What are our customer notification requirements, and is there any other regulatory information we should be aware of?
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We believe that before closing a branch, you must notify your customers and primary federal regulator (the FDIC). Additionally, we recommend reviewing your policies for branch closings and checking your account agreements for additional notification requirements. Under the Federal Deposit Insurance Act, an insured depository institution proposing to close a branch must submit notice to…
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Is there any requirement to notify the Illinois Department of Financial and Professional Regulation (IDFPR) when we close a branch?
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No, we are not aware of any requirement to notify the IDFPR when you close a branch.
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We are a small bank, and several of our employees have been diagnosed with COVID-19. We have two employees on site who are maintaining daily operations and addressing customer needs, but they may have been exposed to the disease. We have been in contact with the FDIC and IDFPR regarding the circumstances, and the IDFPR has advised us of the necessary steps to make an emergency proclamation request and temporarily close our bank. We would like to know if there are any other requirements or regulations we should be aware of in the event of a closure, such as any Uniform Commercial Code (UCC) considerations. Also, we note that our ability to handle the daily cash letter would not be impeded as our correspondent bank handles those operational duties.
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If your bank must close due to a large portion of your employees being diagnosed with COVID-19, we believe you generally would be excused from meeting the time limits imposed by the UCC, provided your bank exercises diligence in taking the necessary action as soon as it is able. Delays by collecting banks and paying…
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We are an Indiana savings bank. We also have branches in Illinois, and we are still open for business but have closed our branch lobbies to foot traffic. We have notified the FDIC and the Indiana Department of Financial Institutions of this modification of our services, and we are planning to send a courtesy notice to the Illinois Department of Financial and Professional Regulation (IDFPR). Where should such notices be directed, and has the IDFPR issued any FAQs for banks or hosted any calls related to the COVID-19 pandemic?
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The IDFPR is accepting notices of modifications in branch services at [email protected]. The IDFPR issued written guidance on lobby closure issues related to the COVID-19 pandemic on March 16, 2020. The IDFPR guidance, copied below, states that banks may close their lobbies in response to the COVID-19 pandemic without obtaining an official proclamation from the…
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Due to renovations of our main office, we will be reducing the number of ATMs in our parking lot from two to one. Do we need to notify the Illinois Department of Financial and Professional Regulation (IDFPR) and/or the FDIC? Are we correct that an ATM is not considered a bank branch subject to branch closing procedures?
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Yes, you are correct that an automated teller machine (ATM) is not a bank branch. Further, we are not aware of any requirement to notify the IDFPR or your primary federal regulator when you remove an ATM. For resources related to our guidance, please see: Federal Deposit Insurance Act, 12 USC 1813(o) (“The term ‘domestic…
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We plan to close the lobby at one of our branches but maintain drive-through services. What should we do about the safe deposit boxes at that branch? We plan to notify safe deposit box customers that the branch will be accessible only via the drive-through and that they can transfer their safe deposit box leases to one of our other locations. How much notice should we provide? What if a customer does not respond to our notice? When can we drill the box?
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We are not aware of any notice requirement for moving safe deposit boxes, unless there is an applicable provision included in your safe deposit box account agreement. Likewise, we are not aware of any law that directly addresses drilling a safe deposit box when the owner is alive and the account is current, which would…