Please help me resolve an issue between my bank's operation staff and our data processor. The data processor has requested that the bank send its work to their processing center before 2 p.m. on Christmas Eve and New Year's Eve. However,this does not jibe with our closing hours. Both the main bank and the branch location close at 3 p.m. on Tuesdays (except for the drive-in which is open until 7 p.m.). Morever, according to our Reg. CC disclosures, the cut-off hour is 3 p.m. on a business day that we are open.
To pacify the data processor, operations management wants to make the cut-off hour on Christmas Eve and New Year's Eve 12:00 noon. I don't think that a 12:00 noon cut-off time is compliance with the regs. I researched the OBRE's website for info on this subject but didn't find a definitive answer in 205 ILCS 630/17. Can anyone provide me with the right answer to resolve this problem? Thanks!

We have had to do the same for day-before holidays in the past. We typically post signage at the teller windows stating that on x date, we will only process current day transactions until x o'clock. Keep an eye on overdrafts the following day and if a deposit was made, forgive and forget.

Your definitive answer is based on federal, not state law. Reg CC at 12 CFR 229.19(a)(5)(ii) indicates your cut-off time for lobby transactions cannot be before 2:00 pm. Thus, on Christmas eve, your Reg CC dislcosure will be wrong, but you would be violating the regulation regardless of what it said.

Anonymous' advice is steeped in the practical; make adjustments so no customer is affected by the violation.

Any customer who makes a deposit prior to 3:00 pm on Tuesday the 24th is entitled to have the 24th treated as the banking day of deposit. You could 1) on Thursday the 26th research every NSF check (inclearing and over the counter) to see if the drawer made a deposit Wednesday afternoon or 2) celebrate the holidays by not only paying every NSF check presented but waiving the fees as well!

Clearly, it would still be a violation of Reg CC and you could be cited for it.