Consecutive Days Off & Branch Closure Obligations

Today’s post covers two topics relevant to credit union operations: consecutive days off and branch closure requirements.

Consecutive Days Off 

While many credit unions may have a policy that requires all employees to be away from the credit union for a certain number of consecutive days there is nothing in NCUA regulations that require credit union employees to use leave for a set amount of days. However, NCUA does consider it to be a useful internal control. 

Currently, the NCUA Examiner’s Guide identifies requiring employees to take at least five consecutive days of vacation each year as an example of an internal control used by credit unions. This practice is intended to support effective oversight. 

In addition, the Examiners Guide discusses consecutive days off as an internal control that may be used as part of a credit union’s risk management practices for combatting fraud. The guidance in the Examiner’s Guide recommends that credit unions require at least five consecutive days of vacation for certain employees, including front-line, accounting, internal audit and other relevant staff particularly when other monitoring controls are not in place.

While not required, taking consecutive leave has long been encouraged by the NCUA. However, the recommended duration has varied over time - for example, a now-unavailable 1996 letter to credit unions suggested that employees take at least one consecutive week of leave, and preferably two weeks.

Branch Closure Obligations

We occasionally receive questions regarding branch closure requirements and any notice requirements because of the changes or closure. There is no federal requirement that credit unions provide advance notice to members of changes to branch hours or closing their offices.

In 2020, NCUA released Letter to Credit Unions 20-CU-02, which stated,

“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.”

Based on the above, changing branch hours or closing a branch temporarily for a short period of time would be an operational decision to be made by the credit union and may be addressed in the credit union’s branch operation policy.

Credit unions have also asked about notice requirements when changing branch hours or closing a branch. These decisions are generally operational and member service matters rather than regulatory requirements. Notification practices may be addressed in credit union policy such as the credit union’s branch operations policy. Even when not required by policy, credit unions may choose to notify members as a service consideration. Advance communication of the change or closure would likely help support a smooth transition and minimize disruption to members. The method and timing of member communications is generally a business decision for the credit union based on its policies, operational considerations, and member needs.