Topic: Disaster Preparedness
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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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Are we allowed to close our branch lobbies during the Coronavirus (COVID-19) pandemic while keeping our drive-through, night drop and electronic banking services available and allowing customers to call for an appointment at a branch? We have a branch with a lobby, night drop and ATM, but no drive-through — would we be allowed to close this lobby? We would put information about the closures on our doors and on our website. Is anything else needed, and should we contact our regulators?
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We recently were advised by the Illinois Department of Financial and Professional Regulation (IDFPR) Division of Banking that banks are permitted to close their lobbies in response to the Coronavirus (COVID-19) pandemic without obtaining an official proclamation from the IDFPR — provided the branches remain open in some matter (for example, by providing drive-through teller…
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We are a state bank and are creating a pandemic disaster recovery guide for our retail department. Is it mandatory for us to make safe deposit box entry available, and must we provide mailed ten-day certificate of deposit (CD) renewal notices? Are there any guidelines for reducing our typical services to a minimum?
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Generally, your obligations to your safe deposit box customers will be dictated by the terms of your safe deposit box rental agreements, and Regulation DD dictates the disclosures you must provide to consumers with CD accounts. However, in the event of a viral pandemic, your bank’s ability to provide certain services or to comply with…
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One of our branches has frequent power outages, generally lasting for less than two hours. Our policy is to close a branch when it has no power. If we notify the IDFPR for each outage, we may be notifying them two or more times per month. Is there a de minimis time period for which we do not have to report a branch closing?
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Yes, your bank must contact the IDFPR and post a notice for the temporary closing of a branch due to a power outage. Illinois’ Banking Emergencies Act requires a state bank to notify the Secretary of the IDFPR as promptly as possible when experiencing an emergency that requires the bank or a branch to close.…
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Can you point us to guidance on creating a special loan program for customers affected by natural disasters? Do you know if there is any funding available for such a program?
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Since your primary federal regulator is the Federal Reserve, we recommend reviewing its guidance on “Supervisory Practices Regarding Banking Organizations and their Borrowers and Other Customers Affected by a Major Disaster or Emergency.” The guidance identifies several ways in which banks may meet their customers’ credit needs, such as by “easing credit terms for new…
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We’re updating our emergency closing procedures. When we have to close a branch or change our branch hours, which agencies should we notify? The FDIC said we don’t have to call them when we contacted them this week.
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We agree that you do not need to notify the FDIC when you close a branch during a banking emergency. The Banking Emergencies Act authorizes the Illinois Department of Financial and Professional Regulation (IDFPR) to issue proclamations that permit banks in Illinois to close or alter their hours due to banking emergencies. 205 ILCS 610/2.…