Question: How often do we have to pick up ATM deposits, and how long after we have picked up these
deposits must they be processed?
Answer: The answer is influenced by the requirements of Regulation CC, which defines when a deposit is
considered received in §229.19(a), and when the funds from such a deposit must be made available in
§§229.10 and 229.12.
If the ATM is on or within 50 feet of bank premises, a deposit is considered received on the day it is made,
with a cutoff hour of no later than 12 noon local time. Because funds deposited in the form of government
checks must be made available on the next business day, notwithstanding the fact the deposit
was made at an ATM, these deposits must effectively be removed for examination daily.
If the ATM is located at least 50 feet away from bank premises, and if deposits are removed no more often
than twice a week (and you notify customers of that fact), a deposit is considered received on the day it is
removed from the ATM. For remote ATMs, then you could remove deposits once a week if you wish. Doing
so, in my opinion, provides less than adequate customer service, however.
Image processing and truncation at the ATM promise to offer efficiencies in providing deposit service for
remote ATMs, in the era of Check 21.
The original version appeared in the September/October 2004 edition of the Oklahoma Bankers Association Compliance Informer.
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