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#1034817 - 09/04/08 06:51 PM
Re: Privately owner ATM's and like
P*Q
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Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
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PM me with your e-mail address and I'll send you our procedures.
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#1035112 - 09/05/08 03:21 AM
Re: Privately owner ATM's and like
devsfan
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Member
Joined: Feb 2006
Posts: 53
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Our institution recently had an exam and though the privately owned ATMs were identified and the accounts are being reviewed it wasn't part of the policy. It was considered in the enhanced due diligence section. Devsfan, I will me you with the my email for your procedures.
My question is, the BSA Manual indicates -- Reviewing corporate documentation, licenses, permits, contracts, or references, including the ATM transaction provider contract -- how far do you go with this and how does this affect the risk? Will they really give you this information?
Thanks
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#1035151 - 09/05/08 12:04 PM
Re: Privately owner ATM's and like
horizon
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Power Poster
Joined: Oct 2003
Posts: 2,548
Southeast
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"My question is, the BSA Manual indicates -- Reviewing corporate documentation, licenses, permits, contracts, or references, including the ATM transaction provider contract -- how far do you go with this and how does this affect the risk? Will they really give you this information?"
We ask for all of that. If they do not give it to us, we close the account.
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Politicians are like diapers. They need to be changed often and for the same reason.
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#1035185 - 09/05/08 12:48 PM
Re: Privately owner ATM's and like
Retread
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Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
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We request a copy of the agreement, try to do a site visit and then monitor the activity. This has passed regulatory muster so far.
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#1035712 - 09/05/08 06:02 PM
Re: Privately owner ATM's and like
devsfan
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Gold Star
Joined: Jun 2008
Posts: 285
South
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We haven't seen anyone unwilling to provide copies of 3 months of ISO statements and a contract, where applicable. We rate them as higher risk if they have more than a handful of ATMs, and if the ATMs are located far away from our locations or our customer's locations, and if the ATMs are located in HIDTAs or other high-risk areas.
One customer thought to have one convenience store was discovered to be operating a dozen convenience stores, each with its own ATM, owned and operated by the customer. No problem with getting the documentation, though. The only one who was squirelly was one who suddenly had to change the name of his business (a year after opening his account) when we started asking questions about his ATM activity. I see some similar behavior with MSBs sometimes - you get them on the phone and ask about check-cashing, and all of the sudden, they don't know anything about check-cashing because they are in the process of selling the business to someone else from the same country.
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"It is natural to give a clear view of the world after accepting the idea that it must be clear." - Albert Camus
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#1037799 - 09/09/08 05:33 PM
Re: Privately owner ATM's and like
Maytagman
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Power Poster
Joined: Jul 2002
Posts: 6,726
the sandy shore
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On this topic, does anyone know anything about MetaBank in Storm Lake Iowa? Funds to a known private ATM account are being ACHed from here, and a search of ACHs reveal another customer receiving funds from/through the same bank, in patterns indicative of another potential, previously un-identified private ATM.
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I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.
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#1037899 - 09/09/08 06:34 PM
Re: Privately owner ATM's and like
Retread
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Power Poster
Joined: Jul 2002
Posts: 6,726
the sandy shore
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Possible, I found that one too.
_________________________
I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.
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#1138180 - 03/02/09 02:48 PM
Re: Privately owner ATM's and like
devsfan
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Gold Star
Joined: Nov 2005
Posts: 440
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I would also like a copy of your ATM procedures. We just found out that we have 2 privately owned ATM's and we don't have any procedures nor are they included in our Risk assessment of products and services. What are the major concerns with privately owned ATM's? How do we know if an ISO is involved. I really appreciate the help.
Last edited by lstark; 03/02/09 03:37 PM.
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#1138260 - 03/02/09 04:22 PM
Re: Privately owner ATM's and like
devsfan
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New Poster
Joined: May 2006
Posts: 18
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I've recently come across a privately owned ATM and am at a loss. Would you mind sharing your procedures with me as well?
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#1138972 - 03/03/09 04:56 PM
Re: Privately owner ATM's and like
divadee
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100 Club
Joined: Mar 2007
Posts: 137
Nebraska
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Ditto - they would be helpful! Thanks
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#1157756 - 04/03/09 08:59 PM
Re: Privately owner ATM's and like
Steve Doty
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Member
Joined: Jan 2004
Posts: 90
Ohio
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Same here, could I have a copy of the procedures?
Thanks
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#1158319 - 04/06/09 05:19 PM
Re: Privately owner ATM's and like
lmaizel
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Junior Member
Joined: Aug 2007
Posts: 45
Florida
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Pizza Queen,
Our policies follow along with Devsfan and Maytagman. A site visit is a definite along with copies of statements and contract. We did end up closing an account for a non-cooperative customer who we discovered had a private ATM in a casino (she never told us about this one) and did not want to provide documentation we requested. I would hesitate to offer services to a customer, as Maytagman said, whose ATMs are located far from their business locations.
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#1167844 - 04/22/09 02:08 PM
Re: Privately owner ATM's and like
complybsa
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Power Poster
Joined: Apr 2005
Posts: 4,013
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We have a few privately owned ATMs, that is, they purchase the machines and them set them out in all kinds of places: bars, hotel lobbies, malls, etc. they are rated (forever) high risk. Each month branch takes a total of cash outs and ACH ins. Should come close. If you see a major blip on one side but not the other that means some cash appeared and fell from the sky, and this would need an explanation. Also, a major blip in a non-blip time (for example, increased usage should be expected on holidays) that should prompt more questions. S&S had no problems with this. that being said, I hate these companies!
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#1167888 - 04/22/09 02:51 PM
Re: Privately owner ATM's and like
complybsa
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Diamond Poster
Joined: Aug 2005
Posts: 2,313
Living in the land of Oz
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The same with our customer. So it is hard to determine what is happening because of the ATM and what is the normal course of business.
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#1184342 - 05/15/09 02:24 PM
Re: Privately owner ATM's and like
Ready to Retire
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Power Poster
Joined: Jan 2004
Posts: 2,795
Guess
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I would like to reopen this discussion. Doesn't anyone consider this to be overreaching on the part of FinCEN? Why should banks, simply because they have a loan relationship or deposit relationship with an entity that has an ATM onsite be responsible for monitoring the activity of that ATM?! I can see it if we are supplying cash for the ATM, but just because an ATM is on their premises does NOT mean we have to play investigator and policeman on it. Let the feds pressure the states to require licensing and inspection of those ATMs. I swear, if we don't start saying "no" on occassion, we're all going to regret it.
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Sorry, did I just use my outside voice?
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#1184381 - 05/15/09 02:52 PM
Re: Privately owner ATM's and like
YosemiteSamIAm
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Power Poster
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
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I personally think that much of what we do in the investigative arena qualifies as "over reaching". But that is now our reality. Obviously, the primary goal of monitoring ATM operations is to ensure that they are not being used to launder ill gotten gains. We need to understand where the money being loaded into our customer's machine is coming from if it isn't coming from us. And is the money they are withdrawing from us really being used for ATM purposes. Pretty consistent with the other cash flow monitoring we are required to do. And actually it is a necessary piece of the cash flow puzzle for a multi-faceted, cash intensive business.
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Life without Jesus is like an unsharpened pencil - it has no point.
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#1184460 - 05/15/09 03:49 PM
Re: Privately owner ATM's and like
BrendaC
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Georgia Plum
Unregistered
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It's called job security and today I am thankful for that!
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#1184466 - 05/15/09 03:54 PM
Re: Privately owner ATM's and like
YosemiteSamIAm
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Doesn't anyone consider this to be overreaching on the part of FinCEN? I agree with your conclusion, but will not put the fault at FinCEN's feet. They are a co-author of the Handbook, but each of the five families also participates in the development process. The historical precdent is MSBs. Initially, the FDIC's examination procedures made their supervised institutions the de facto regulatory agency for MSBs. They never anticipated the backlash; i.e. that banks would simply say "We're not doing that" and summarily close MSB accounts. Retread acknowledges that "no documentation, no account" is a policy his bank is willing to enforce. As for me, I agree. I would follow every Mickey Mouse suggestion my regulator offers, but I'm passing every dime of the cost on to the customer; e.g. "If you provide financial services, whether it is cashing checks or offering an ATM, here's your fee schedule."
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#1184494 - 05/15/09 04:05 PM
Re: Privately owner ATM's and like
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100 Club
Joined: Dec 2005
Posts: 116
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Is the question meant to ask if the ATM activity does not touch the institution, should there be any monitoring performed?
In my opinion, if we get the ACH credits OR see the cash withdrawals (preferably both, obviously), then most definitely we should be aware if the cash flow is not as it would be expected. The only way to know that is to investigate/monitor to make sure that it is.
I think if the ATM money is flowing completely through another institutions, aside from wondering why we don't have the entire relationship, it is still a piece of information I would want to know about. Knowing all services offered by one of our customers is vital information not only in BSA land, but in other areas of the institution also. I don't think I would give the account the same depth of review as the businesses that have ATMs that are serviced through an account here, however knowing that they have an ATM on the premises would give me enough cause to be aware of the activity in the relationship 'just in case'.
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In order to discover who you are, first learn who everybody else is. You're what's left. -A Fortune Cookie
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#1184509 - 05/15/09 04:16 PM
Re: Privately owner ATM's and like
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Power Poster
Joined: Jan 2004
Posts: 2,795
Guess
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It's called job security and today I am thankful for that! All this "job security" is going to send me to an early grave...where's the "plus" in that?
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Sorry, did I just use my outside voice?
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