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#1711306 - 06/18/12 04:21 PM Reg D
amberleigh Offline
Junior Member
Joined: May 2011
Posts: 34
Kansas
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.
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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.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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