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#1174 - 04/02/01 09:07 PM Final Rule on Reg E - ATM disclosures
jbest Offline
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jbest
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Can someone clarify this for me? I'm reading the final rule on Reg E concerning the ATM disclosures. Do we have to post a notice on the machine and on the screen disclosing our ATM fees or can it just be posted on the screen? Our ATMs that do not have a screen have our notice regarding fees taped to the machine. It was my understanding that you just have disclose the fees in your initial disclosure and post on the atm either by paper or on a screen , not both.

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#1175 - 04/02/01 09:57 PM Re: Final Rule on Reg E - ATM disclosures
John Burnett Offline
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The "surcharge" notice at the ATM must be in two places:

1) At the machine, which means it's on a physical posting. (Note: If this gets vandalized, GLBA amendment protects the ATM deployer from liability.)

2) On the screen prior to consumer committing to the transaction. If incapable of putting on screen (you said you are not capable since your machine has no screen), the notice must be on a slip of paper that gets delivered to customer before committing to transaction.

If you can neither display on screen nor print the notice on receipt, you get grandfathered until 12/2004. But I really find it hard to believe there are still such machines around! (But I'm willing to learn!)

E-Mail me for more details. jsburnett@ccbt.com


[This message has been edited by John Burnett (edited 04-02-2001).]

[This message has been edited by John Burnett (edited 04-02-2001).]

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#1176 - 04/03/01 02:37 AM Re: Final Rule on Reg E - ATM disclosures
Andy_Z Offline
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John didn't mention the banks disclosure. The bank also has to tell customers that they may have to pay surcharges.

From the final rule:
The amendments require ATM operators that impose a fee for providing electronic fund transfer services to post a notice in a prominent and conspicuous location on or at the ATM. The operator must also disclose that a fee will be imposed and the amount of the fee, either on the screen of the machine or on a paper notice, before the consumer is committed to completing the transaction. In addition, when the consumer contracts for an electronic fund transfer service, financial institutions are required to provide initial disclosures, including a notice that a fee may be imposed for electronic fund transfers initiated at an ATM operated by another entity.

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Andy Zavoina
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#1177 - 07/11/01 01:56 AM Re: Final Rule on Reg E - ATM disclosures
Anonymous
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This goes into effect on October 1, 2001 right? Is there a CA law that also requires a notice on or at the ATM? We already disclose the surcharge on screen.

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#1178 - 07/11/01 03:29 AM Re: Final Rule on Reg E - ATM disclosures
Andy_Z Offline
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I can't address the CA law issue, but this requirement exists now, but is optional until Oct. 1.

Many network rules have required notifications for some time, especially on the screens.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

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AndyZ CRCM
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R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1179 - 07/11/01 01:13 PM Re: Final Rule on Reg E - ATM disclosures
John Burnett Offline
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John Burnett
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Several networks have had notice requirements in place for years (well, since 1996, when this all began).

It's interesting to note that four substantial banks are finally bringing suit in federal court to overturn the last bastion of surcharge bans -- Iowa!

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#1180 - 07/12/01 04:17 AM Re: Final Rule on Reg E - ATM disclosures
Princess Romeo Offline

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Yes - in California this notice requirement has already been in place. The only additional requirement was the Reg E disclosure where we have to tell our customers that if they use someone else's ATM, they may face an additional charge from that ATM operator.
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