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A Banker's Guide to Virtual Currency
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BSA/AML Compliance: Writing the SAR Narrative
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Required Training for Loan Originators
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Overdraft Practices in Today's Regulatory Environment
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Reg E Claims - Allocating Liability Correctly
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#1539885 - 04/22/11 04:12 PM Banks sued for lack of signage
califgirl Offline
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Registered: 03/04/02
Posts: 2226
Loc: The O.C., California
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eBanking / Technology
#1540015 - 04/25/11 08:45 AM Re: Banks sued for lack of signage [Re: califgirl]
John Burnett Offline
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Registered: 10/27/00
Posts: 29431
Loc: Cape Cod
Defensive strategies:

(1) Make sure that the notice required by Regulation E 205.16(c)(1) is posted on or at the machine. Take a dated digital photo of the notice and machine and note its location. If your camera provides GPS location position info, make sure that's recorded, too. If a sign is defaced or removed by someone other than the ATM owner (a vandal or one of these opportunist plaintiffs, for example), the Electronic Fund Transfer Act provides a safe harbor, but you have to document that the notice was actually posted to get it.

(2) Make a check of the notice a priority item on the ATM servicing checklist. Have its presence documented each and every time the machine is serviced. If the notice is missing, get someone to replace it ASAP. Document that it is again posted (see item (1)).


Edited by John Burnett (04/25/11 08:45 AM)
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