We are going to be using Interactive Teller Machines - Does anyone have experience with this new techology and have recommendations on issues that should be considered for compliance?

I searched for previous threads on this topic and there is not much to go on.

Any comments on this matter will be appreciated.

Some of the larger banks consider these the branches of the future. Interaction with a live person via video, but having no lobby or drive through available.

In that sense, it could be considered a branch.

Are there any Bankers out there that have ITMs that could provide some insight?

Never installed, but took a long hard look at them.

ATMs are ATMs so follow the normal guidelines for ATMs.

As far as the video customer service, treat it the same as your customer service phone number, web chat, or other remote service channel. You'll have capacity considerations for long video chats, so you might opt to only keep the audio or purge video on the same timeframe you purge your customer service phone recordings. Even though it is interactive that doesn't make it any different than a normal ATM with the ability to call customer service. I can shadow/emulate a user in online banking and make that experience interactive... doesn't make it a branch.

If the Interactive Teller Machine (ITM) scans the checks and captures them into the ITM, The remote teller views the check images real time and the ITM creates an X.9 virtual copy, is the transaction considered Reg. E or Check 21? The bank will have the original check and destroy them once the transactions post. It could be a period of time before they are destroyed, but not sure what others do.

Any input is appreciated.