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#765099 - 06/29/07 06:01 PM ATM Closing
CO Officer Offline
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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 08:18 PM Re: ATM Closing CO Officer
IAuditCompliance Offline
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Joined: Sep 2004
Posts: 50
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 01:50 PM Re: ATM Closing CO Officer
AnonRegulator Offline
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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 11:29 PM Re: ATM Closing AnonRegulator
Mrs. Rizzo Offline
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Curled up by the fire...
I'm gonna go with anon on this one
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#1573364 - 07/01/11 08:59 PM Re: ATM Closing Mrs. Rizzo
ahou Offline
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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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#1586595 - 08/02/11 08:53 PM Re: ATM Closing ahou
dg Offline
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Posts: 811
Pacific NW
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 11:40 PM Re: ATM Closing dg
rlcarey Online
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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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#1592252 - 08/16/11 10:43 AM Re: ATM Closing IAuditCompliance
Tennismom Offline
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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 11:10 AM Re: ATM Closing Tennismom
Kathleen O. Blanchard Offline

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For CRA purposes I would. You should justify why that service was discontinued in an LMI tract, how it affected residents, etc.
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#1592443 - 08/16/11 05:07 PM Re: ATM Closing Kathleen O. Blanchard
Tennismom Offline
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As always.....THANKS

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