By Donya Parrish, MCU VP Risk Management
As the holidays roll around each year, a common question gets repeated — are we allowed to close the credit union on a holiday that the Federal Reserve Bank doesn’t observe? Despite rumors to the contrary, yes you are! (Who started that myth anyway?)
Now, there are a couple things to keep in mind that can impact compliance. Let’s use the Friday after Thanksgiving as an example of a day many credit unions choose to give their staff the day off.
Since the FRB sends ACH and check files on any day they are open, your credit union should strongly consider having someone post those files on the day received. If you choose not to and they are posted on the following day you are open, you may be outside your timeline to return any problem items. The return timelines are not based on when the credit union is open, but on when the files are sent to the credit union.
In addition, you could also be creating issues for your members with payroll and other credits they are expecting (especially on Black Friday!) or with debits hitting their accounts after other funds have been spent.
To see the official Federal Reserve holiday calendar — that does differ from the federal government schedule at times — visit https://www.frbservices.org/about/holiday-schedules. Note that 2021 is a year that Christmas Day falls on a Saturday, so they do NOT observe the preceding Friday as a holiday.
With any closure, notice by all possible manners is recommended to alert members ahead of time. Other than that, lace up your shopping shoes to take advantage of deals, unless of course you are the one working solo posting the ACH files!