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Financial Services Law Insights and Observations

New Hampshire regulator provides guidance on branch closures, annual meetings, and examinations

State Issues State Regulators Covid-19 New Hampshire Credit Union Examination Liquidity Standards

State Issues

On March 13, the New Hampshire Banking Department (NHBD) issued a memorandum to state-chartered banks, credit unions, and trust companies encouraging them to work constructively with customers experiencing difficulty due to Covid-19 and offering guidance on branch closures, annual meetings, examinations, and liquidity. Banks and credit unions do not need prior authorization to use only the drive-through portion of a branch or adjust normal business hours but must submit applications to the NHBD for branch closures in excess of 48 hours. If necessary, credit unions may conduct annual meetings via video or teleconference and both banks and credit unions may request adjustments to examination schedules or additional time to respond to consumer complaints. Finally, institutions are asked to closely monitor liquidity levels in the event of higher than normal consumer cash withdrawals and ensure sources of liquidity are readily available.