Topic: Branch Closing
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Are there any Illinois notice requirements regarding extending our hours at one of our branches? We plan to notify our customers about the change.
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No, there are no notice requirements under Illinois or federal law regarding an expansion of branch hours, although we agree that it would be prudent to post advance notice of the changed hours in your main bank and branch lobbies. Your bank also may wish to update relevant advertising, listings and other information to reflect…
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We would like to close a few branches at noon one day a week. We plan to notify our customers of the change, but want to confirm if there are any timing requirements for the notice. Also, we are considering other changes to accommodate staffing shortages, such as closing a branch lobby one extra day a week, but keeping the drive-thru open. Or locking the lobby one day a week, but permitting customers to come in if they walk up to the door. Does either action require us to notify the IDFPR?
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No, there are no specific notice or timing requirements regarding a reduction in branch hours. However, we agree that it would be prudent to notify customers in advance and to review your account agreements to see if they include any relevant customer notification requirements. You also may consider updating relevant advertising, listings and other information…
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Does the Illinois Promissory Note and Banking Holiday Act require that we remain open at least four days a week? What does the law require to close a branch one day a week on a regular basis or to reduce the hours at a branch? We plan to notify our customers in advance of our planned changes and check our account agreements for any language that might address our hours of operation.
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The Illinois Department of Financial and Professional Regulation (IDFPR) has interpreted the Illinois Promissory Note and Bank Holiday Act to require banks to remain open at least four and a half days each week. According to the IDFPR, a bank may close on Sundays and at noon on Saturdays without notice. In addition, a bank…
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We are closing a branch to remodel for a couple of days. I believe I should notify the IDFPR and post a lobby notice. Is that right, and is there anything else I need to do?
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We agree that your bank should comply with the procedures for branch closings under the Illinois Promissory Note and Bank Holiday Act, which requires Illinois banks to take three steps before one-time closings such as this: (1) adopt a resolution authorizing the closure; (2) send a copy of the resolution to the Illinois Department of…
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We are considering closing a couple of our branches for one afternoon a week. Are there any rules that would apply to a bank reducing its hours? We are running the change by our CRA officer.
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No, we are not aware of any laws or regulations that expressly address a reduction in branch hours. We do recommend checking your account agreements to ensure that they do not include relevant notification requirements. We also recommend posting advance notice of the changed hours in your main bank and branch lobbies, as well as…
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We plan to close some of our branches on a day we normally would be open in order to allow our employees to attend a day-long volunteer event. What do we need to do in order to close those branches for that day? The day we want to close is not a holiday, and we are a state-chartered bank.
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The Illinois Promissory Note and Bank Holiday Act requires Illinois banks to take three steps before a one-time closing such as this: (1) adopt a resolution authorizing the closure; (2) send a copy of the resolution to the Illinois Department of Financial and Professional Regulation; and (3) conspicuously post a notice in the lobby of…
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We recently had to close a branch early for a few hours due to no air conditioning in extreme heat. We posted a notice, but I think that we also should notify the IDFPR. Is that correct, and who should we contact at the IDFPR?
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Yes, we recommend contacting the IDFPR and posting a notice for an early closing of a branch due to extreme heat and a nonfunctioning air conditioning system. Even though your branch was not closed for an entire day, we believe use of these procedures is appropriate; an early closing will affect customers who wish to…
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We are contemplating closing a branch that has rented safe deposit boxes. We plan to notify safe deposit box customers that we are closing the branch, and that they can transfer their safe deposit box accounts to a new location. Customers who wish to do so will remove their safe deposit box contents themselves. For customers who do not respond to our notice, we plan to drill the boxes, remove and inventory the contents, and then hold the contents in the vault of another branch. Our attorney has suggested that we video record the box openings, in addition to having two employees present, in order to defend against any claims that items are missing. Do you have any additional guidance on how we should handle safe deposit boxes for customers who do not respond to our notice?
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We agree that you should guard against potential claims that items are missing if you open any safe deposit boxes and transfer their contents without customer approval, and we think your bank counsel is providing you with sound advice in this regard. We do recommend that you review your safe deposit box agreement to determine…
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We are updating our branch closing policy and have several questions. Is it correct that notifying the IDFPR of a branch closing is a courtesy, not a requirement? Also, do we have to receive permission from our primary regulator to close a branch? Or do we simply have to provide them with notice? If we do notify our primary regulator of a branch closing, will the notice be made public? Finally, can you confirm whether we are required to publish notice in the newspaper or merely to notify our customers in writing?
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You are correct that there is no statutory requirement to notify the IDFPR when you close a branch. You are also correct that you must notify — but not obtain permission from — your primary federal regulator prior to closing a branch. Your notice will not be made public, but the fact that you have…
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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.