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#1874071 - 11/25/13 04:33 PM Privately Owner ATMS
sturner Offline
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Joined: May 2010
Posts: 103
Arkansas
I have a MSB that now has an ATM. They fund, service, and balance the ATM themselves. I have gotten all these questions answered along with a copy of the ATM contract. Is there any other kind of due diligence, etc. that I need to do with this? Another possible issue with this is that the account they use for all ATM transactions is with another bank, not our bank.

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#1874120 - 11/25/13 06:02 PM Re: Privately Owner ATMS sturner
MagicCity Offline

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MagicCity
Joined: Apr 2003
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Fort Lauderdale, Florida
Do they also use another bank for their non-ATM MSB activities?
If they do, then you do not have an accurate/complete picture of their activities.

I would not be comfortable banking them if I could not see the entire picture.

Did they say why that portion of the business is at the other bank?

With MSBs I look at their cash out vs the checks deposited, - having them take part of that cash now to fund an ATM will skewer those numbers.

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#1874211 - 11/25/13 09:05 PM Re: Privately Owner ATMS sturner
sturner Offline
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Joined: May 2010
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Arkansas
No, their other MSB activities (cashing checks) runs through our account.

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#1874237 - 11/25/13 09:52 PM Re: Privately Owner ATMS sturner
MagicCity Offline

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Fort Lauderdale, Florida
Do you analyze the activity monthly by looking at the volume of cash out vs. the checks they deposit with you?

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#1874240 - 11/25/13 09:55 PM Re: Privately Owner ATMS sturner
Elwood P. Dowd Offline
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Next to Harvey
If you do not have the account for the ATM at your bank you are simply crippled in any efforts to evaluate that activity. It is increasingly common that banks require customers with private ATMs to maintain the clearing account at their bank.
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#1874599 - 11/26/13 11:05 PM Re: Privately Owner ATMS sturner
sturner Offline
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Joined: May 2010
Posts: 103
Arkansas
Yes, I analyze their cash activity on a monthly basis and do a more in depth review quarterly.

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#1874696 - 11/27/13 04:21 PM Re: Privately Owner ATMS sturner
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
Sturner: when you state that "They fund, service, and balance the ATM themselves" do you also mean that the ACH credits for the ATM usage come to their account with you? If yes then you know the cash needed to replenish the ATM each day and you could see how much cash they are withdrawing from you for the ATM and also the check cashing. If the ACH credits do not come to you then as Ken stated you cannot know how the ATM is replenished which is why these are high-risk for BSA purposes.

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#1876293 - 12/05/13 04:12 PM Re: Privately Owner ATMS sturner
CantBeShocked Offline
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Joined: Apr 2006
Posts: 260
MS
If you receive the ACH credits for ATM transactions at your bank, then I would require them to also fund the ATM with cash from your bank. in addition, I require the ATM ACh credits and cash withdrawals to be made in a separate individual account where only the ATM transactions occur. That is the only way you can monitor the MSB activity and the ATM activity individually and separately to see the flow of funds in regards to each separate type of high risk activity.
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#1885600 - 01/10/14 10:04 PM Re: Privately Owner ATMS CantBeShocked
SouthoftheBorder Offline
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Joined: Feb 2002
Posts: 335
The South
Are the owners of the ATM's considered MSB's? Requiring registration?

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#1885617 - 01/10/14 10:26 PM Re: Privately Owner ATMS SouthoftheBorder
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
No. The "triggers" for being classified as an MSB do not mention ATMs.
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#1885685 - 01/11/14 10:08 PM Re: Privately Owner ATMS sturner
rlcarey Offline
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rlcarey
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Galveston, TX
However, some States do have registration/licensing requirements for ATM owners which might be part of a bank's due diligence process.
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