I would treat the closing of an ATM that accepts deposits the same as if you were closing a branch. Regulators will look at that as a service that is now lost..esp if it is w/in a LMI area.
How would you treat an ATM whose deposit accepting capability is discontinued, especially in a LMI census tract? In short, the ATM will no longer accepting deposits. Although the ATM is still present, a service (accepting deposits is now lost). Internally should we treat this similar to a branch closing (justification for discontinue of service, etc., etc.)?