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Financial Services Law Insights and Observations

Minnesota Commerce Department instructs banks on temporary closures

State Issues Covid-19 Minnesota Credit Union Bank Compliance

State Issues

On March 12, the Minnesota Commerce Department issued guidance on emergency closures for banks, and a similar guidance for credit unions.  In an emergency (including for Covid-19 or other pandemic, related conditions), officers have the authority to decide not to open or to close an already open office, but prior approval is needed for closures lasting more than 48 hours, excluding legal holidays. The Department should be notified of closures as soon as practical. On March 17, the Department issued a clarification that a bank is not considered closed if it elects to close the lobby but maintains drive-through service or if the lobby is open (i.e., not by appointment-only basis) but not immediately accessible due to locked doors.