We are going to Same Day Banking cut-offs. However, our various branches and regions have different closing times.

Is the best way to approach this in our disclosure to list the cut-off/closing time of each one of our branches or can we just say the cut-off time is when the branch closes?

In researching I came across the following:
B. 229.16(b) Content of Specific Policy Disclosure
6. ... If a bank does not have a cut-off time prior to its closing time, the bank need not disclose a cut-off time.

Since our closing time is our cut-off time then we do not have to disclose a cut-off time at all even though our branches have varying closing times. Am I correct on this?

Also - it is my understanding that we do not have to "POST" our cut-off time at all in our lobby. If applicable it would just have to be in our Funds Availability Disclosure. Correct?

Correct on both questions.

Thanks Randy!