Question: One of our commercial customers wants us to waive fees for the use of the ATM in their store. We currently pay them a rental fee to have the ATM there. The receipts from the customers would be given to the store, who will give them to us. We'll refund the fee to the customer and reduce our rental payment by the same amount. Are there problems with this?
Answer: The issue here is Reg E. You must make receipts available to the customer under §205.9.
While you could say it was available and they gave it up, I'd recommend instead using some automated routine that refunds your customers at that machine. A monthly report total should serve the needs of the store and the rental agreement. This could save everyone time, and still be compliant and customer friendly.
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