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September 8
Checkup for your RDC Program;
Susan Orr

September 10
Critical Issues on Certificates of Deposit;
Deborah Crawford

September 16
S.A.F.E. Act - Auditing for Compliance;
Patricia Cashman

September 22
FinCEN's Beneficial Owners Proposal: What It Can Mean for You;
Sonja Kriegsmann and John Burnett

September 23
Bankruptcy 101;
Sam Ott

September 24
Using CPTED to Make Our Banks Safer;
Dana Turner and Carol Dodgen



Topic Options
#765099 - 06/29/07 02:01 PM ATM Closing
CO Officer Offline
100 Club

Registered: 02/03/03
Posts: 199
Loc: USA
Does the closing of a ATM (which accepts deposits) require prior notification to customers or our regulator?

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CRA
#765499 - 06/29/07 04:18 PM Re: ATM Closing [Re: CO Officer]
IAuditCompliance Offline
Member

Registered: 09/15/04
Posts: 50
Loc: Midwest
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.

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#768129 - 07/05/07 09:50 AM Re: ATM Closing [Re: CO Officer]
AnonRegulator Offline
Gold Star

Registered: 03/02/02
Posts: 450
Loc: Everywhere, USA
Check with your primary regulator on this, but I believe the closing of ATMs does not require an advance branch closing notice. The reason is that ATMs are not considered branches for purposes of this advance notice requirement. AR.

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#769175 - 07/05/07 07:29 PM Re: ATM Closing [Re: AnonRegulator]
Mrs. Rizzo Offline
10K Club

Registered: 03/07/06
Posts: 10385
Loc: Curled up by the fire...
I'm gonna go with anon on this one
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#1573364 - 07/01/11 04:59 PM Re: ATM Closing [Re: Mrs. Rizzo]
ahou Offline
Power Poster

Registered: 08/15/02
Posts: 2695
You do not have to notify your regulator when removing an ATM.

Notice is not required for the closing of a nonbranch facility, such as an ATM, a remote service facility, a loan-production office, or a temporary branch.
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Opinions are my own and not of my employer.

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#1586595 - 08/02/11 04:53 PM Re: ATM Closing [Re: ahou]
September Offline
Platinum Poster

Registered: 01/28/05
Posts: 750
Loc: Anywhere the snow falls :)
Are you saying that a loan production office is not a branch? If so, where is this definition? We are FDIC regulated and openening a loan production office. Am finding very little on the reqyuirements are nonrequirements of an LPO. Any guidance would be appreciated.

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#1586687 - 08/02/11 07:40 PM Re: ATM Closing [Re: September]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49743
Loc: Galveston, TX
Read this:

http://www.fdic.gov/regulations/laws/rules/5000-3830.html

Since you appear to be a State bank, you also need to check on State law requirements.
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The opinions expressed are my own, take them or leave them.

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#1592252 - 08/16/11 06:43 AM Re: ATM Closing [Re: IAuditCompliance]
tennismom Offline
Gold Star

Registered: 01/14/04
Posts: 486
Originally Posted By: IAuditCompliance
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.)?

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#1592255 - 08/16/11 07:10 AM Re: ATM Closing [Re: tennismom]
Kathleen B Online

10K Club

Registered: 12/27/00
Posts: 17349
For CRA purposes I would. You should justify why that service was discontinued in an LMI tract, how it affected residents, etc.
_________________________
Kathleen Blanchard CRCM "Kaybee"
Lending/CRA/HMDA/Mapping/Consulting
www.kaybeescomplianceinsights.com

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#1592443 - 08/16/11 01:07 PM Re: ATM Closing [Re: Kathleen B]
tennismom Offline
Gold Star

Registered: 01/14/04
Posts: 486
As always.....THANKS

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