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#632542 - 11/01/06 11:11 PM change in branch hours of operation
gadawg1 Offline
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Joined: Sep 2006
Posts: 419
Georgia
We are reducing the hours in two of our branches. Do we have to notify our regulator FDIC? Do we have to post the change in hours at the branch and if so, how many days prior to the change? Do we need to send out a notice to all customers prior to the change? Thanks for your help.

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#632543 - 11/02/06 03:21 PM Re: change in branch hours of operation
SavannahOne Offline
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Georgia
The FDIC considers this a "reputation" issue between you and your customers.

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#632544 - 11/02/06 04:17 PM Re: change in branch hours of operation
LauraL Offline
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Posts: 365
Georgia
You need to avoid posting the same question in two forums please. The moderators don't like it.

I believe you must alert all existing customers about the change at least 30 days prior to the change. That would include posting a sign in all branches about the change in hours of the one branch.
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#632545 - 11/02/06 05:32 PM Re: change in branch hours of operation
Bagweaver Offline
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SW GA
Doesn't this fall under reduction in service under CRA? Wouldn't you have to determine the impact on the customers of those branches and decide alternatives for their "lost" banking services - for example: another bank branch located within a mile of the closing branch.

I don't know that you'd have to post signage in all branches, but I know that you'd want to post at least 30 days prior in the affected brances. Check with your regulator.

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#632546 - 11/02/06 08:43 PM Re: change in branch hours of operation
LauraL Offline
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Georgia
I thought the reduction in service under CRA was for "closing" a branch, but I could be wrong.
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#632547 - 11/03/06 04:06 PM Re: change in branch hours of operation
SavannahOne Offline
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Georgia
It is for closing a branch.

Whata - What type of reductions are you talking about? IE: Closing at 4pm rather than 5pm and Opening at 9am rather than 8am - Or closing all days other than on Wednesday from 11am to 2pm?

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#632548 - 11/03/06 04:13 PM Re: change in branch hours of operation
gadawg1 Offline
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Joined: Sep 2006
Posts: 419
Georgia
The reduction in hours would be closing 2 branches on Saturday.

Thanks for everyone's help on this.

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#1639300 - 12/15/11 01:53 PM Re: change in branch hours of operation gadawg1
RR Joker Offline
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Has anything changed on requirements for changing hours for Georgia? Another bank here said you had to post it in the paper, but to my knowledge, if you are reducing hours and eliminating Saturday drive-thru, for instance, it only needs to be posted or should be posted for 30 days in the affected branches.
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#1639331 - 12/15/11 02:33 PM Re: change in branch hours of operation RR Joker
waldensouth Offline
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FINALLY ABOVE the gnat line
Reduction in Services - means exactly that. CRA covers both closing the branch and reducing the services customers receive at that branch. Your CRA officer needs to have a file with the justification - i.e. low customer impact - numbers thru door just not sufficient, etc..


You do not have to post it in the paper - just in your lobby.
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#1639332 - 12/15/11 02:36 PM Re: change in branch hours of operation waldensouth
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Thanks, Walden...I don't know where the other bank came up with that...they are supposed to be sending us their source on it.

Thankfully, I was aware of the CRA end...I just need to make sure we document it.

Thanks!
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#1639945 - 12/16/11 02:02 PM Re: change in branch hours of operation LauraL
RR Becca Offline
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out of the frying pan...
Originally Posted By: LauraL
That would include posting a sign in all branches about the change in hours of the one branch.


If one branch wants to close earlier by one hour on Fridays, we have to put a notice in all the branches, even in other towns? That seems excessive.
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#1639978 - 12/16/11 02:47 PM Re: change in branch hours of operation gadawg1
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I believe it's only required in the affected branch...look at Bagweaver's response above as well. It really doesn't seem to be covered anywhere in GA code...I feel like it's a 'best practice' requirement at best as it is. Obviously, you would want to post...but not everywhere!
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#1640873 - 12/20/11 01:50 PM Re: change in branch hours of operation RR Joker
Bagweaver Offline
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SW GA
Make sure that whatever reason(s) you give you have numbers to back it up - # transactions not sufficient to justify expense of being open. Determine the cost of each transaction on average. Alternatives could be visiting other close by branches, night drop, ATM, online banking.

Make sure everything is spelled out for the regulators prior to their visit so that you aren't scrambling at exam time to justify what the bank has done.
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#1848908 - 09/05/13 01:10 PM Re: change in branch hours of operation Bagweaver
lds1958 Offline
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O.k. I need to tag on to this and ask if we have already reduced our hours in one of our branches from our lobby being opened from 5 days a week to our lobby being opened one day per week a few months ago and now management wants us to just close the lobby completely to traffic and only have a drive thru facility at that branch would we still just have to post a notice in the lobby of that branch and do our CRA study/documentation with no statement notice sent and no notice in the paper? Do we have to notify DBF just as good measure or is that not necessary?

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#1848920 - 09/05/13 01:22 PM Re: change in branch hours of operation gadawg1
waldensouth Offline
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FINALLY ABOVE the gnat line
You need to document the reasons for your CRA file, post in the lobby of that branch for 30 days and that's it. You may make a courtesy notice to the GADBF if you like. Everyone's CRA policy should contain a procedure for reducing services as well as closing an office.
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#1848922 - 09/05/13 01:25 PM Re: change in branch hours of operation waldensouth
lds1958 Offline
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Thanks Walden!!

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