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#359995 - 05/16/05 08:45 PM Banking Hour Changes
Sound Tactic Offline
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Sound Tactic
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We have a rural bank location that will be changing its hours to mornings only. Previously they were open from 8 to 4 during weekdays. The cutoff time will be effected by this change. Does anyone know what compliance implications the cutoff time and any other disclosure requirements are needed.

I am sure we will be disclosing the changes as a customer service issue, but I am affraid there may be some unforseen compliance requirements.

Thanks in advance
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General Discussion
#359996 - 05/16/05 09:05 PM Re: Banking Hour Changes
Reads Regs Offline
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This will affect your funds availability disclosure.

The following is the text of comment 6 of the Official Staff Commentary to section 229.16 Of Regulation CC.

"6. The business day cut-off time used by the bank must be disclosed and if some locations have different cut-off times the bank must note this in the disclosure and state the earliest time that might apply. A bank need not list all of the different cut-off times that might apply. If a bank does not have a cut-off time prior to its closing time, the bank need not disclose a cut-off time."
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#359997 - 05/16/05 09:15 PM Re: Banking Hour Changes
Sound Tactic Offline
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Sound Tactic
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Thank you Reg Reader. Does anyone know of any other implications?
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#359998 - 05/16/05 09:36 PM Re: Banking Hour Changes
Anonymous
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Since we are making a change that is probably considered "adverse" to the customer, do we need to give them minimum notice before the change?

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#359999 - 05/16/05 09:51 PM Re: Banking Hour Changes
Anonymous
Unregistered

Reg CC 229.18 requires 30 days advance notice to holders of consumer accounts before implementing a change to the bank's availability policy that is adverse to a customer. Since the business day is being substantially reduced, I would provide 30 days advance notice.

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#360000 - 05/16/05 09:58 PM Re: Banking Hour Changes
HRH Dawnie Offline
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HRH Dawnie
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Anchorage Alaska
Review how this effects CRA service levels as well. You need to be sure to keep your CRA staff in the loop so they can explain the change to the examiners.
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#360001 - 05/16/05 10:23 PM Re: Banking Hour Changes
Andy_Z Offline
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How early are you going to make it? (You refer to "mornings only.") I would refer you to 229.19 6.a. which for the lobby can't be before 2, as I read it.
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#360002 - 05/17/05 01:05 PM Re: Banking Hour Changes
Sound Tactic Offline
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Sound Tactic
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Thank you all very much, I did not forsee the last two posts. But all have helped. If anyone can think of any more, please let me know.
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