Topic: Promissory Note and Bank Holiday Act
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If a branch has only one teller, and a customer comes in to make a deposit during one of the teller’s breaks, is that a problem? Should we post a sign during the teller’s breaks?
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We do not believe that any Illinois or federal laws would impose a notice requirement during times when no tellers are available to transact business. Regulation CC would not impose any notice requirements, as it explicitly does not “require a depositary bank to open or otherwise to make its facilities available for customer transactions on…
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If one of our branches is already closed on Saturdays (which are half-holidays under Illinois law), can we also close the branch on another day of the week (say, Thursdays)?
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Based on guidance we received from the Illinois Department of Financial and Professional Regulation (IDFPR), we do not see a problem with remaining closed two days per week, on Saturdays plus another day (such as Thursdays). The Promissory Note and Bank Holiday Act states that a bank may “select any one day of the week…
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Are there any regulations/approvals or time frames we would need to be concerned with if we reduce our current drive up hours? Lobby hours would remain unchanged.
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We are not aware of any laws that address a reduction in hours for a drive-up facility, and we can only make suggestions as to reputation risk and CRA risks. The Illinois Promissory Note and Bank Holiday Act imposes duties when a bank plans to close a branch on a particular day each week, but…
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We are looking at changing our hours of operation at several of our locations. Are there any notification requirements in Illinois that are required prior to this change?
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We are not aware of any laws that address a reduction in branch hours, and we can only make suggestions as to reputation risk and CRA risks. The Illinois Promissory Note and Bank Holiday Act imposes duties when a bank plans to close a branch on a particular day each week, but it is silent…
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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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If we are closing all new branches after we acquire them to convert them to our systems, how should we notify the state?
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The Illinois Promissory Note and Bank Holiday Act establishes the procedure for closing the bank on a single occasion. 205 ILCS 630/17(c). To close on a particular day, the board of directors must adopt a resolution authorizing the closure, you must send a copy of the resolution to the Department of Financial and Professional Regulation,…
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What disclosures should we make before moving up the cut-off time for check deposits to noon on Saturdays?
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The Promissory Note and Bank Holiday Act already permits banks to close at noon on each Saturday. 205 ILCS 630/17. Also note that the cut-off hour for the receipt of deposits may be no earlier than 2:00 p.m. (or 12:00 p.m. for ATMs) under Regulation CC, but you do not have to accept deposits after…
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What disclosures should we make if we will be opening a branch on Thursdays that was previously closed on Thursdays?
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As to the branch that you will be opening on Thursdays, the Illinois Promissory Note and Bank Holiday Act requires a resolution by the board of directors that terminates their prior resolution to close that branch on Thursday. The resolution must be certified by an officer in charge of the bank’s records. Further, the Act…
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Do we have to give notice of closing the bank for a holiday that lands on a Saturday?
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Under the Illinois Promissory Note and Bank Holiday Act, banks are permitted to close at noon on each Saturday and all day on Sunday. Banks may also remain closed on the holidays that are specified in the Act, which include the first day of January but not the last day in December. Therefore, you would…
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If we are reducing the business hours for one of our branches, do we need to be aware of any CRA issues?
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We are not aware of any laws that address a reduction in branch hours, and so we can only make suggestions as to reputation risk and CRA risks. The Illinois Promissory Note and Bank Holiday Act imposes duties when a bank plans to close a branch one day per week, but it is silent as…