ATM Privacy Notice
by Lucy Griffin, BOL Guru
Guru Bios
Question: Our auditors have written up as a violation the fact that we do not have a GLB privacy notice on our ATM. I didn't think this is a requirement. Is this a violation? If so, where is the regulation that requires it?
Answer: This is a wonderful example of invent-a-rule, a common source of compliance misunderstandings and imaginary violations. While there are ATM notice requirements, most notably in Regulations CC and E, there is no requirement that a GLB privacy notice be posted on the ATM. Someone got over-enthusiastic or confused and invented a rule that doesn't exist.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 8, 8/04
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