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#1711306 - 06/18/12 04:21 PM Reg D
amberleigh Offline
Junior Member
Joined: May 2011
Posts: 34
Do withdrawals at foreign ATMs (not our bank's ATMs), count against the customer for Reg D purposes or are those withdrawals considered in person?

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Operations Compliance
#1711323 - 06/18/12 04:34 PM Re: Reg D amberleigh
Doug Hendrickson Offline
Power Poster
Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
Withdrawals made at an ATM are not counted against the customer for Reg D purposes. I don't believe there is any distinction in the regulation as to whether or not the ATM is the bank's or a foreign ATM.
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1711897 - 06/19/12 07:01 PM Re: Reg D amberleigh
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,598
Cape Cod
Whether the ATM is at your bank or in Istanbul, those withdrawals don't need to be counted.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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