Compliance Q&A: Holiday Hours

Valerie Moss
December 17, 2008 | COMMENTS

Question: Staff members often debate whether the credit union can close for more than three consecutive days during the holiday season. Is there any federal regulation limiting the number of consecutive days a federal credit union can remain closed?

Answer: No. No federal law or regulation prevents a federal credit union from being closed for more than three consecutive days. However, some states have laws dealing with "emergency closings," closing days, or holiday closings, and may limit state-chartered institutions from closing for more than three consecutive days.

State-chartered credit unions should check with their state credit union leagues concerning similar state statutes that could affect operating hours.

There are several things to keep in mind if you're planning a longer than usual closure during the holidays. From a safety and soundness perspective, federal regulators prefer that federal credit unions and national banks stay open for business long enough to provide sufficient service to members and customers, and to remain competitive with other local financial institutions.

Additionally, when these financial institutions are closed on days other than weekends or national holidays, they must consider the impact of other laws, such as the Uniform Commercial Code, state and federal labor laws, and access to the Federal Reserve Banks. When closed for a national holiday, the entire staff can be off.

However, when closed on a day that isn't a national holiday, at least some employees in back-office departments should be working to clear checks before the midnight deadline, deal with wire transfers, release funds availability holds on deposits, and perform other required functions.

Valerie Moss is director of compliance information for the Credit Union National Association. This story first appeared at www.creditunionmagazine.com and is reprinted with permission.