As the holidays approach, many credit unions have questions about consecutive day closings. For example, a credit union might like to close for Thanksgiving, Nov. 24 and remain closed until the following Monday, Nov. 28. Is that allowed?
According to CUNA compliance staff, the answer is yes, per federal law. Despite popular claims that financial institutions are not allowed by law to close for 4 or more consecutive days, such a law does not exist at the federal level. However, credit unions are encouraged to investigate as to whether or not a state law in its jurisdiction speaks to this subject.
When determining it’s holiday schedule, a credit union should keep member service in mind as well as its other obligations under federal law. Credit unions should consider if staff must be present to clear checks, release funds availability holds or perform other required functions.
For example, Regulation CC, which deals with the availability of funds and collection of checks, provides for the following:
In addition, the new same-day automated clearinghouse (ACH) rule that went into effect Sept. 23 requires a receiving depository institution to make an ACH credit available no later than the end of its processing day.
For additional details on consecutive day closings, see CUNA’s CompBlog.