Legal Q&A: Are Banks Required To Provide Notice When Changing Lobby Hours?

By Scott Birrenkott

Q: Are Banks Required To Provide Notice When Changing Lobby Hours?

A: Not by rule or law, but some form of notification is recommended.

There exists no specific requirement to notify bank customers, or its regulators, when changing its hours of operation. This includes branch hours, lobby hours, drive up hours, or other times of access, such as whether a location is open on a Saturday.

However, specific requirements do exist for closure of branch banks, requiring notice in writing to the Wisconsin Department of Financial Institution (DFI) at least 30 days in advance of the closure, along with notices in the bank’s lobby which is to be closed. While such notice is not required for a change of hours, bank might consider following that procedure as a matter of courtesy and update to DFI, even though it is not closing a branch.

Additionally, while no specific notice requirement to customers exists, some form of communication would be prudent. For example: a posting in lobbies, through mail, or online via the bank’s website, social media, or other applications, would likely be beneficial and appreciated by those customers who use the affected lobbies, drive-ups, deposit box, etc.

Lastly, the bank should also consider the implications of its change of hours. While there might not be specific notice requirements related to the shift in hours alone, if the shift in hours affect other areas, additional requirements may apply. For example, if cutoff times are changing, or funds availability, stop payment, or other time-sensitive matters are changing, the bank may need to update its disclosures and any associated deposit account rules.

If you have any questions on this topic or other matters of compliance, contact WBA’s legal call program at 608-441-1200 or wbalegal@wisbank.com.

Note: The above information is not intended to provide legal advice; rather, it is intended to provide general information about banking issues. Consult your institution’s attorney for special legal advice or assistance.