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We are changing our Bank lobby hours on Saturday. All lobbies will be closed leaving only the drive thru open. Are there any specific disclosures we are required to post or give? We are putting a signage at the branch for 30 days and putting information on the Bank statement remarks. We are giving FDIC the appropriate notice. Are there any additional state notice requirements or other federal requirements?
We know this will affect our ROR timing and some TRID disclosure timing requirements, is there any other areas we need to address?KRS 286.3-180(6) (http://www.lrc.ky.gov/statutes/statute.aspx?id=14547) discusses giving 90 days notice, to the Commissioner of FI, if any operation of the branch is discontinued. I did not see a definition for operation and I’m not sure how this is interpreted or enforced by the KDFI. You could take the safe approach and provide the 90 days notice or contact them to find out what is required.
You would also want to consider how it could affect CRA and document the Change/reduction in hours/services in your public file.
228.43(a)
(5) A list of services (including hours of operation, available loan and deposit products, and transaction fees) generally offered at the bank’s branches and descriptions of material differences in the availability or cost of services at particular branches, if any. At its option, a bank may include information regarding the availability of alternative systems for delivering retail banking services (e.g., ATMs, ATMs not owned or operated by or exclusively for the bank, banking by telephone or computer, loan production offices, and bank-at-work or bank-by-mail programs);
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