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#1825456 - 06/20/13 02:19 PM ATM or Cash Dispenser?
SunnyFL, CRCM Offline
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Joined: Sep 2004
Posts: 205
Situation: Customer has re-cycling business. When someone brings in materials for re-cycling, it is weighed and they receive a ticket. Ticket is then taken to cash dispensing machine for payment.

FFIEC ATM description says "Most dispense currency, but some dispense only a paper receipt (scrip) that the customer exchanges for currency or goods."

Question #1: Would you agree that our customer would qualify as having a privately owned ATM based on this description?
Question #2: How would you monitor when this does not settle through the customers account like an ATM would? We could see withdrawals for cash to fill the machine but that is about it.

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#1825471 - 06/20/13 02:30 PM Re: ATM or Cash Dispenser? SunnyFL, CRCM
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
Whether you call it an ATM or a cash-dispenser, the result is the same -- the business is paying out cash in excess of the cash it brings in. It's a net cash user, not a net cash supplier. That would be the situation whether the cash is paid out from the "till" or from this machine, whatever you call it. Now your challenge becomes how you monitor cash used by the business and determine whether those cash payouts are reasonable and expected based on your knowledge of the business, its volume, and its peer businesses.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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