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#111996 - 09/04/03 02:25 PM Reg E Change in terms notification
Anonymous
Unregistered

My bank has a number of deposit taking ATMs, as well as several non-deposit taking ATMs. The bank would like to discontinue the "deposit taking" feature at ONE of its locations.

I just want to confirm that no formal change in terms notification is required under Reg E in this instance.

Thanks!

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Operations Compliance
#111997 - 09/04/03 02:34 PM Re: Reg E Change in terms notification
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I am assuming you have already included the exculpatory "not all services are available at all locations" language in your disclosures.

No formal change in terms notice is required because you're not changing the services available to your customers. You might consider, however, posting a notice at the ATM in question for a couple of weeks prior to and after the change is implemented.
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John S. Burnett
BankersOnline.com
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#111998 - 09/04/03 03:00 PM Re: Reg E Change in terms notification
Anonymous
Unregistered

Yes. We have that language in our disclosure. Thanks for your input.

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#111999 - 09/04/03 03:01 PM Re: Reg E Change in terms notification
reinkesd Offline
100 Club
reinkesd
Joined: May 2003
Posts: 232
Connecticut
We did this about a year ago and gave 30 days notice at the ATM by posting a sign saying "as of this date we will no longer accept deposits at this ATM". Then, we gave them alternate locations to take their deposits. There were a few squawkers, but overall pretty uneventful. We left the notice there for a few months afterwards also for those that may have missed it.

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#112000 - 09/04/03 08:59 PM Re: Reg E Change in terms notification
complyguy Offline
Gold Star
complyguy
Joined: May 2001
Posts: 494
PA
A non-notice consideration might be whether the ATM is located in an LMI area where you do not have other deposit facilities.

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