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Change in Branch Bank's Operating Hours
Answer by John Burnett and Randy Carey, BOL Gurus
Guru Bio
Question: What disclosures are required for changing a branch's hours? Specifically having one branch not open on Saturday when only the drive through was open so it's not a banking day for Reg CC.
Answer by John Burnett: Saturday wouldn't be a banking day for Regulation CC regardless of what you have open. That's because a banking day has to first be a business day, and Saturdays and Sundays cannot be business days under Regulation CC. All of that aside, I'm not aware of any particular federal regulatory requirement that you post disclosures when you change a branch's hours. It's simply good business sense to alert customers in some way. Often a notice is posted in the lobby of the affected branch for a reasonable time before the change is effective.
Answer by Randy Carey: Checking your state law is also advised. For example in Oklahoma:
602.1 Closing of location other than main office
If a bank, credit union, or savings association has one or more detached facilities or branch offices or deposit production offices or loan production offices, those facilities, branches, or loan production offices may be open at times and on days which are different from the hours and days the main office is open, as specified in the organization's plan. Notice of a change in hours or days of operation should be furnished to customers to the extent practicable.
First published on BankersOnline.com 3/24/08
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