I have been asked to research how adding third party depository ATMs will affect our CRA AA. We have a third party vendor who we contract for ATM withdrawal service. We are looking to include deposit functions to these ATM’s.

I have looked at the geographic definition in the Reg and as I read it; we will need to list all of the ATM’s with deposit capability on our assessment area maps. However, we do not own these ATM’s. They are contracted and serviced by a third party vendor. And they are in many 7-11’s all over the country.

To complicate matters, 6 of the ATM’s are local to us, situated in a Costco, and have our institution’s “Branding” on them. These are also serviced and owned by a third party. We would also like to include depository functions on these as well.

We do not report them now. Will adding the depository function cause this to change?

bump

What is the bank's connection to the ATMs that are not branded?

They provide a fee free withdrawal service that is contracted to many other banks as well. Similar to the Cirrus, Allpoint, etc. chain of providers. The 'branded' ATM's are also part of that network; we just pay to have our name on them

So you are just joining a network of ATMs?

If the branded ones are already in your AA, you should list them but they won't change your AA.

We are already part of that network and have been. The new kink is that the ATM's are going to start offering deposit services instead of just withdrawals. Does that addition of services constitute reporting requirements for us, based on the fact that they are not exclusive to the bank, but will be considered deposit-taking. I guess I need clarification on whether the ability to take deposits on these machines would change whether we would report or not report, and if available, could you reference any cite that we could use to support our conversation with Marketing?

As long as they are the network ATMs and not your bank's own ATMs they would not affect your AA. Otherwise, every bank in the network would be listing the same ATMs.

I do think the branded ATMs will need to be listed but as you said, they are already in your AA.

You could call the CRA folks at your regulator to get confirmation; they are generally very helpful.

Thanks KB...as always, you have been very helpful!

Happy to help you think it through!