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#2002743 - 03/19/15 07:30 PM ATM Site Visits
Bankoholic Offline
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Joined: Feb 2015
Posts: 1
Lexington, SC
I am interested in knowing what other financial institutions are looking at/for when conducting site visits for Privately Owned ATMs. Does anyone have any type of checklist?

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#2002751 - 03/19/15 07:40 PM Re: ATM Site Visits Bankoholic
rlcarey Offline
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Galveston, TX
Site visits? Boy, they must be pretty high volume ATMs to warrant site visits.
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#2002977 - 03/20/15 04:22 PM Re: ATM Site Visits Bankoholic
MagicCity Offline

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Fort Lauderdale, Florida
We do an annual site visit on all customers with private ATMs even though they are all small and not high risk.
It is a form that just confirms each year the number of ATMs they have, and the expected activity.

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#2003130 - 03/20/15 08:42 PM Re: ATM Site Visits Bankoholic
Pat Patriot Act Offline
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Like it or not, recent enforcement actions show that the FDIC has pushed this control for high risk customers in general.

If you are implementing these, it may be useful to use a general cash-intensive business site visit control to determine if you can observe any other higher risk business activities (e.g. check cashing, wires, etc.) occuring at the place of business.

As rlcarey implied, there's not much to check for if you're just looking at the ATM. It might look like this:

1. Is ATM still there? Yes / No

Signature:
Date:
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#2003136 - 03/20/15 08:56 PM Re: ATM Site Visits Pat Patriot Act
rlcarey Offline
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Galveston, TX
Originally Posted By: patsfan
Like it or not, recent enforcement actions show that the FDIC has pushed this control for high risk customers in general.


True, but to go visit the local bar that has a ATM that processes a couple hundred dollars a week in business is pretty much a waste of time.

Now, as you say, if you are talking about a high risk customer - including the ATM look see in relationship to a general site visit, that is appropriate risk management.
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#2003407 - 03/23/15 07:33 PM Re: ATM Site Visits rlcarey
MagicCity Offline

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Fort Lauderdale, Florida
Quote:
True, but to go visit the local bar that has a ATM that processes a couple hundred dollars a week in business is pretty much a waste of time.


About 90% of what examiners ask for today fits into this category.
We are all pretty much applying a BSA-on-steroids program, but no examiner is going to say you are doing fine, or doing enough.
So each exam brings another nugget of ridiculousness to the process. IMHO.

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#2003755 - 03/24/15 08:51 PM Re: ATM Site Visits MagicCity
Princess Romeo Offline

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Where the heart is
Originally Posted By: MagicCity
Quote:
True, but to go visit the local bar that has a ATM that processes a couple hundred dollars a week in business is pretty much a waste of time.


About 90% of what examiners ask for today fits into this category.
We are all pretty much applying a BSA-on-steroids program, but no examiner is going to say you are doing fine, or doing enough.
So each exam brings another nugget of ridiculousness to the process. IMHO.


You can never be too rich or too thin or have conducted enough due diligence.
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Regulations are a poor substitute for ethics.
Just sayin'

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#2003759 - 03/24/15 08:54 PM Re: ATM Site Visits Bankoholic
rlcarey Offline
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Joined: Jul 2001
Posts: 83,356
Galveston, TX
And a bank can never call the ombudsman too many times either smile
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#2003815 - 03/25/15 11:47 AM Re: ATM Site Visits Bankoholic
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
Or utilize the bar while checking.
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#2003819 - 03/25/15 12:39 PM Re: ATM Site Visits Bankoholic
HappyGilmore Offline
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Posts: 19,854
Pulling people out of the ditc...
or complain about the stupid regulations that are put in place because people can't be expected to be responsible for their own actions
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#2004816 - 03/27/15 08:36 PM Re: ATM Site Visits Bankoholic
Indy Banker Offline
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Joined: Aug 2010
Posts: 528
or complain about the hypocrisy of the Federal Government, i.e. over 100,00 Federal workers delinquent on unpaid taxes, amounting to $1.14 billion owed (and HUD workers with the highest Federal income tax delinquency rate at over 4%)...Secretary of State opts for a private e-mail server due to "convenience"...and it goes on and on.

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