ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
ADVERTISEMENT
Home Compliance and Risk

Whom Should I Notify if My Branch’s Hours Are Changing?

June 4, 2018
Reading Time: 3 mins read

By Leslie Callaway, CRCM, CAFP; Mark Kruhm, CRCM, CAFP; and Rhonda Castaneda, CRCM

Q My bank is changing its branch lobby hours to close 30 minutes earlier, although the drive-through hours will remain the same. What public notice must the bank post and what is the timeframe? Does the bank need to notify its regulator prior to implementing this change?

A The bank needs to check state law, but federal law has no requirements related to banking hours unless the reduction results in the branch being considered as closed.

You should have the decision to reduce hours reflected in the minutes of the board of directors and, although not legally required, it is always a good idea to notify your examiner-in-charge via a “courtesy” letter. (And don’t forget to update your Community Reinvestment Act public file!)

For the convenience of the bank’s customers, the bank should post a notice in the branches affected. The bank can decide how much advance notice is appropriate, but if any affected branches contain safe deposit boxes, the bank should provide longer advance notice. Some states require written notice when safe deposit box hours are affected. (Response provided March 2018.)

• • •

Q Our bank is making a loan secured by an old farmhouse and some other structures, of which only the outhouse and an old chicken coop are located in a special flood hazard area. The property will not be used for agricultural purposes. Is the bank required to obtain flood insurance on the low-value outhouse and chicken coop? If so, how much flood insurance should the bank require given that neither building has much value?

A It depends. For example, if the two structures are not affixed to a permanent site, they are not “buildings” under the rule. Thus, the loan would not be subject the flood insurance coverage requirements.

Even if they are affixed, they may be excluded from coverage under the “detached structure” exemption for structures that: (1) are part of a residential property (e.g., not used for agricultural purpose); (2) are detached from the primary residential structure; and (3) do not serve as a residence.

If, however, the buildings/structures are not eligible for one of these or other exclusions, the bank must determine whether there is any “insurable value” associated with the buildings or if they are otherwise insurable. If so, they would technically require flood insurance coverage even though the value may be low. It may be prudent to consult with a flood insurance professional. ABA continues to request guidance from the regulatory agencies on this matter as well as advocating for legislative reforms to address this and other issues. (Response provided March 2018.)

• • •

Q My bank has a Native American population, some of whom would like to open accounts at my bank. The issue is that they do not have a physical address, as they live on the reservation and there are no “911 addresses” there. (We use the 911 address for CIP purposes.) Is there another option that we can rely on in order to meet the needs of these individuals?

A FinCEN recognized that there will be occasions when a bank does not have a physical address like 123 Main Street. For example, in a footnote to the requirement (footnote 47 of the BSA/AML Examination Manual), servicemembers can use an Army Post Office or Fleet Post Office address. The footnote goes on to state that it’s possible to use the residential or business street address of next of kin or of another contact individual, or a description of the customer’s physical location.

Also, see the FinCEN January 2004 FAQ, which states that that banks could use a rural route number which, unlike a post office box number, describes the approximate area where the customer can be located. The FAQs go on to state that a description of the customer’s physical location is sufficient.
Although it’s not specifically addressed in the existing guidance, you should be able to use the address of the reservation since that’s consistent with the regulatory requirements. Note, however, that if your bank does not currently use this alternative, then your bank’s current CIP policy will need to be updated and reapproved by your board. (Response provided March 2018.)

 

Answers are provided by Leslie Callaway, CRCM, CAFP, director of compliance outreach and development; Mark Kruhm, CRCM, CAFP, senior compliance analyst; and Rhonda Castaneda, CRCM, compliance analyst, ABA Center for Regulatory Compliance. Answers do not provide, nor are they intended to substitute for, professional legal advice. Answers were current as of the response date shown at the end of each item.

ADVERTISEMENT
Tags: Bank branchesFlood insuranceKnow your customer
ShareTweetPin

Related Posts

FBI: Crypto-related fraud losses increased 45% in 2023

Justice Department seizes millions of dollars linked to alleged crypto investment scams

Compliance and Risk
June 20, 2025

The Department of Justice announced it has seized $225.3 million in funds linked to cryptocurrency investment scams. The action marks the largest cryptocurrency seizure in Secret Service history.

ABA urges FinCEN to reevaluate BOI collection burden on banks

FinCEN releases figures on BSA filings

Compliance and Risk
June 20, 2025

Financial institutions filed 4.7 million suspicious activity reports in fiscal year 2024. They filed 20.5 million currency transaction reports during the same time frame.

FinCEN to propose new rules on money laundering, whistleblower program

Treasury official outlines principles for Bank Secrecy Act modernization

Compliance and Risk
June 18, 2025

The Treasury Department is exploring ways to streamline the filing process for suspicious activity reports and currency transaction reports as part of a broader effort to modernize BSA enforcement, Deputy Secretary of the Treasury Michael Faulkender said.

ABA suggests splitting proposal to expand Fedwire, NSS operating hours

FATF releases revisions to international standard for payment transparency

Compliance and Risk
June 18, 2025

FAFT announced several revisions to its recommendation on payments transparency, which it said will enhance the safety and security of cross-border payments to better detect financial crime.

BAFT releases report on best practices, guidance for ISO 20022 migration

CFPB to delay small-business lending data collection compliance dates

Compliance and Risk
June 17, 2025

The CFPB will issue an interim final rule today to push back by roughly a year the compliance dates for its small-business data collection requirements, according to a filing in the Federal Register.

Is deepfake technology shifting the gold standard of authentication?

Will fraud prevention ever be autonomous?

Technology
June 17, 2025

Anti-fraud systems are learning to anticipate fraud rather than merely react to it. Better anticipatory abilities inch systems closer to full automation.

NEWSBYTES

ABA DataBank: Planned/announced office conversions spike

June 20, 2025

OCC releases mortgage performance report for Q1 2025

June 20, 2025

Justice Department seizes millions of dollars linked to alleged crypto investment scams

June 20, 2025

SPONSORED CONTENT

AI Compliance and Regulation: What Financial Institutions Need to Know

Unlocking Deposit Growth: How Financial Institutions Can Activate Data for Precision Cross-Sell

June 1, 2025
Choosing the Right Account Opening Platform: 10 Key Considerations for Long-Term Success

Choosing the Right Account Opening Platform: 10 Key Considerations for Long-Term Success

April 25, 2025
Outsourcing: Getting to Go/No-Go

Outsourcing: Getting to Go/No-Go

April 5, 2025
Six Payments Trends Driving the Future of Transactions

Six Payments Trends Driving the Future of Transactions

March 15, 2025

PODCASTS

Podcast: Staying close to clients amid tariff-driven volatility

June 18, 2025

Podcast: Old National’s Jim Ryan on the things that really matter

June 12, 2025

Podcast: What bankers need to know about ‘First Amendment audits’

June 5, 2025
ADVERTISEMENT

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2025 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2025 American Bankers Association. All rights reserved.