Dying employed has it's benefits. It beats dying unemployed and hungry.

You guys are just a wellspring of happiness today!

Back to the subject at hand... The customer "feeds" the ATM with cash withdrawn from the bank. The ISO credits the customer's account for the amounts dispensed.

Randy pointed out in a response in this forum a few days ago that the cash dispensing bank could review the ISO's credits to their customer's account as a source of verification. Maytagman, above, mentions getting copies of the statements from the ISO for the same purpose. Either resource, coupled with a review of the amount and cash composition of withdrawals for the same period should provide the dispensing bank with a reasonable, albeit imprecise, reconciliation Trees mentions above. However, it would certainly be easier and more timely if the dispensing bank was able to review its own accounts for receipt of the ACH credits.

Does the ATM owner have any say so about the account the ISO uses to provide reimbursement; i.e. would it be reasonable for the cash dispensing bank to require the reimbursements flow through the customer's business account at that institution or even a separate ATM account as a condition of continuing to do business with the ATM owner?

"would it be reasonable for the cash dispensing bank to require the reimbursements flow through the customer's business account at that institution or even a separate ATM account as a condition of continuing to do business with the ATM owner?"

I think it is more than reasonable. I have several clients that require this as a condition of providing them cash for their ATMs. Similar to how they treat their MSB customers. What it comes down to is the bank demands that they have the whole banking relationship (so that ins and outs can be monitored - although that is not directly communicated to the customer) or they send them down the street.

Does anyone have a sample letter they would be willing to share? I have recently found out we have several customers with an ATM on premises. I'd like to send out a letter requesting various information and would appreciate some ideas. thanks!

Fallgirl, PM me your Bank address and I'll send you the one we recently sent.

I'd like to have a copy of the procedures as well. Thanks.

A new twist just as an FYI. Apparently in my state, any ATM is considered a non-Bank ATM (electronic branch)and it's required that each ATM be registered with the Department of Banking! Not by the store owner, but rather by the ATM processor. Most major or national processors do not know about this requirement so now we have a bunch of customers who are violating state law. Just when I think I get all of my due diligence done, we now have to verify state licensing of these things. This is headed down the MSB road we all traveled a few years ago....GRRRR....

Pam - I don't think it's your customers who are violating Ch. 167B, it's the ATM deployer/processor. For what it's worth, you might simply notify the DOB of your concerns about unlicensed ATMs deployed by "ATMs R Us" or whoever and provide whatever location information you can pull together.

I recently came across this post and if you are still able to provide your procedures dealing with privately owned ATMS I would appreciate a copy. We have just recently seen growth in our area of private ATMs and are finding that some of our convencience store customers have put them in. We don't want to get caught red-faced.

I would also like a copy of the procedures.

On a side note, I just discovered that a customer who has multiple pharmacies with my FI has a privately owned ATM in one location. He confirmed to the branch manager that he is taking money from the register and using it to replenish the ATM. An "ATM/Lotto" account he maintains at my FI then receives ACH credits.

I have already been reviewing the relationship due to the cash deposit activity spread across the accounts he maintains with my bank. The branch manager also confirmed to me that there are no agreements or any documentation of any kind. Any advice on this issue?

That's pretty much what they all say.

Compare his "pre-ATM" deposits and withdrawals of currency to current levels. If he's feeding the ATM with cash received over the counter, his cash deposits should have dropped in an inverse correlation with the increase in ATM derived ACH credits to his account. In addition, find out what denominations his ATM dispenses and compare that to the denominations that make up his deposits. The ATM should be consuming the larger bills.

ACBbank

An "ATM/Lotto" account he maintains at my FI then receives ACH credits.

I recall that there was an regulation with NYS Lotto where the Lotto account could only have direct debits from Lotto. It has been a while since I have seen the reg. and my firewall would not let me check.

You may wish to check.

Are there any state licensing requirements for the privately owned ATM's (or owners)?

There can be. There are in Massachusetts, for example. This is a question you ought to re-post in your state's forum, assuming you're from the Lone Star State.

Thanks John. Will do.

I have just recently signed up for this forum. So far, it seems pretty informative. In line with this particular subject, I am also looking for advice or process/procedures for Privatly Owned ATM's. We recently opened an account for a convenience store specifically to fund their ATM.

Check out the bankers tools page, I shared a checklist that I use.

TBOBTH,

Welcome to BOL. You might want to consider redacting your personal information from your profile. We all did it your way in the beginning, but lessons were learned...

Mine was when a consumer who had visited BOL then called me at home on a Sunday afternoon to ask for advice about a check he thought his bank has mishandled. If he had not called in the middle of the NASCAR race I might have just hung up on him...