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#2279784 - 01/12/23 11:34 PM FDIC Branch Closing Notice
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,266
We are an FDIC bank in the process of reviewing our branch closing procedures. According to Section 42 (see below), we are to ".... submit a notice of the proposed closing to the appropriate Federal banking agency not later than the first day of the 90-day period. Would that be business or calendar days? If business, should we use the Reg Z definition?

SEC. 42. NOTICE OF BRANCH CLOSURE

(a) NOTICE TO APPROPRIATE FEDERAL BANKING AGENCY.

(1) IN GENERAL. --An insured depository institution which proposes to close any branch shall submit a notice of the proposed closing to the appropriate Federal banking agency not later than the first day of the 90-day period ending on the date proposed for the closing.

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General Discussion
#2279788 - 01/13/23 12:17 PM Re: FDIC Branch Closing Notice Mel in WA
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Calendar, when it is not specifically defined. Business days serves no purpose in this sort of notice requirement.
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#2279815 - 01/13/23 04:09 PM Re: FDIC Branch Closing Notice Mel in WA
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,266
Thanks! I was leaning towards business days. Is it standard to assume it's calendar when not defined?

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#2279817 - 01/13/23 04:23 PM Re: FDIC Branch Closing Notice Mel in WA
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
In this case, they use calendar days rather than saying three months advance notice or one month, etc. Typically, yes it would be calendar days when it does not specifically refer to business days or otherwise define what constitutes a day.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2279820 - 01/13/23 04:36 PM Re: FDIC Branch Closing Notice Mel in WA
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,266
Learned something new! Thanks again. smile

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