Coming across various information on banks closing early or not being open at all on a day when the Fed is open. Do at least some amount of Operations staff need to always be working until at least 5:30 PM or so in order to process Same Day ACH transactions, etc.? I know as far as closing, if it is not an OCC regulated bank, it would generally be more dependent on State law/reaching out to the FDIC or Fed and State Regulator. As far as the operations piece, I understand that Reg. CC seems to allow for deposits to be considered received the next banking day in such cases, but what to do with the ACH Same Day with multiple windows is confusing.

you may want to move this to private banker threads, not sure anyone wants to answer where a regulator may view the response if they are "bending" requirements

I'm not asking anything about bending requirements. I'm asking about when a Bank gives December 23rd off or something and the Regulator has no issue with it. Or, when a Bank closes early on such a day.

Nacha rules require that you process your ACH files by the Nacha deadlines, and provide same-day credit without regard for early closings or closings on Christmas Eve, for example. If you do that processing in-house, you need to have staff equipped to complete it.

Thank you John, that's where my research led as well.