Branch Closures/Modifications

What are other credit unions doing about branch/lobby access?

There are many different ways credit unions are accommodating members during this crisis. Here are some examples:

  • Encouraging use of drive-up banking (Very few credit unions have drive-up tellers; many who do have closed branch access and serve members through the drive-up)
  • Limit the number of people in the lobby for social distancing or visiting the branch by appointment only
  • Unrestricted access but using guards to keep crowds down
  • Limit hours of operations (need to post on website and on the branch)
  • Promoting ITM and ATM usage
  • Staffing—with many employees not available to work (caring for children or are sick), some credit unions are “rotating” frontline staff to ease their concerns
  • Increasing call center staffing
  • If you close a branch, or your sponsor closes access to the building, you must notify NCUA regional office and your state regulator (if applicable), and inform your members on how they can access their accounts and credit union services, such as by phone, at ATMs, or via online and mobile platforms

May a FCU restrict access or close its facilities?

Yes. A FCU may adopt reasonable measures to safeguard the health and safety of its staff and members. Credit unions taking these measures, however, should ensure they apply the policy in a uniform and consistent manner. FCUs should follow the direction of any federal, state or local authorities with respect to social distancing or related measures (emphasis added). There is no federal law or regulation that requires FCUs to be open certain hours or days or that would prevent a FCU from closing its offices. Credit unions have the flexibility to make reasonable, good faith decisions to close branches and offer members services available through other channels such as by phone, at automated teller machines, or via online and mobile platforms. This can include situations where advance notice is not feasible as a closure may need to occur quickly. Decisions to close branches can be ratified by the credit union board by email or at the next board meeting. Credit unions do not need to notify NCUA of branch closures unless there is an interruption in vital member services exceeding two days, in which case credit unions have five days to notify their regional director as set forth in 12 C.F.R. 748.1(b). FISCUs may be subject to different requirements under state law or regulation.

Source: NCUA Actions Related to COVID-19; LCU 20-CU-02

May a California State-Chartered Credit Union Restrict Access or Close its Facilities?

Yes. While branch closures are a credit union management’s business decision, the DBO appreciates the need to strike a balance to protect the health and safety of your employees and members with the need to continue to provide critical services to your members. If a CA state licensed credit union does close a branch(es), notify the DBO by providing the names and addresses of the branches that you will be temporarily closing, how you plan to communicate this to your members, and how you plan to ensure that they are able to avail themselves of the credit union’s services without interruption. Federally insured state licensed credit unions should also notify the NCUA if there is an interruption in vital member services exceeding two days, in which case credit unions have five days to notify their regional director. (NCUA Regs Part 748.1(b)). “Vital member services” is defined as informational account inquiries, share withdrawals and deposits, and loan payments and disbursements.

May a Nevada State-Chartered Credit Union Restrict Access or Close its Facilities?

Yes. Although there is no state law or regulation to notify the FID in the event of a branch closure or limited hours, the FID encourages financial institutions to notify the FID of temporary closures of facilities and the availability of alternative service options as soon as practical. This includes when closing the lobby and continuing to serve members through a drive-thru service. Please see the Nevada FID’s Statement regarding the Coronavirus.

For federally insured NV state-chartered credit unions, credit unions do not need to notify NCUA of branch closures unless there is an interruption in vital member services exceeding two days, in which case credit unions have five days to notify their regional director .(NCUA Regs Part 748.1(b)). “Vital member services” is defined as informational account inquiries, share withdrawals and deposits, and loan payments and disbursements.