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January 6, 2015
Business Accounts Documentation and Procedures with Beneficial Ownership
Deborah Crawford

January 6, 2015
FFIEC Cybersecurity Initiatives and Observations from the 2014 Assessments
Susan Orr

January 15, 2015
The ABC's of IRAs - The Basic Ingredients
Patrice Konarik

January 20, 2015
B & Z Appraisal Rules - Getting Them Right
Jack Holzknecht

January 21, 2015
HMDA Soup to Nuts
David Dickinson

January 22, 2015
Navigating the Treacherous Waters of IRA Rollovers, Transfers and Beneficiary Payouts
Patrice Konarik

January 28, 2015
Mortgage Life Cycle
Part I
David Dickinson and Jerod Moyer



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

Registered: 02/03/03
Posts: 200
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: 10390
Loc: Curled up by the fire...
I'm gonna go with anon on this one
_________________________
Take responsibility for your life.

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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: 2724
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.
_________________________
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: 758
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]
Happy Birthday rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 51225
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.
_________________________
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
Platinum Poster

Registered: 01/14/04
Posts: 506
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: 17857
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
Platinum Poster

Registered: 01/14/04
Posts: 506
As always.....THANKS

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