We have a customer who is starting up a number of privately owned ATM machines in various business locations and will be acting as their own ISO. Currently our other customers who own ATM's only have one machine so there is only one machine activity running through a seperate ATM bank account. Which is easy to monitor the money going out of the machine and the withdrawals to load. With this new customer having 25+ machines, what is the best way to monitor through the bank account? Do we need to have a seperate account for each machine or do we request reports from the customer on a regular basis to see the activity of each machine? At present they have one checking account for the ATM activity for all the machines.

I would not require a separate account for each machine and as long as the account with you is used only for the ATMs, with the daily ACH credits for the usage in each machine and the cash withdrawals, which should agree with the ACH credits, I think you are fine. You don't need to receive reports of the ATM usage since the ACH credits tell you the same thing.

Thank you for responding. Just didn't want to miss anything.

Personally, I would not necessarily open a separate account for each ATM. Some people may find it easier to reconcile the customer provided ATM reports this way, but it can be done with one account. I would just use a spreadsheet to throw all the ACH data into. If you export the data from your core, it should include an ATM ID number associated with each ACH credit.

When I hear about a customer starting up multiple private ATMs this comes to mind.

Official Private ATM Guidance

All credits must come to an account at your bank. All cash used to feed the machines must come from your bank. (A contract addressing this issues would be prudent.) Opt out if there is a failure on either point as any monitoring you would do would be the equivalent of a dog chasing its tail.

First tier: Your bank is striving to provide objective support for a belief that you supplied all of the cash withdrawn from the ATMs; i.e. no third party source of cash exists. Here, you are not trying to trace funds to or from individual machines.

Second tier: Internalflora's link is insightful and could add another layer to "monitoring," one that would require you to monitor activity on individual machines. If you conclude that you are responsible for detecting or even interdicting activity like that described there or here or here , you will need to know where the ATMs are located and have some reasonable idea of what their routine withdrawals might be. Whether you could do that from an omnibus account would be determined entirely by your operational capabilities.

It sounds as if this customer relationship is one that has evolved into something that was not contemplated when the account was opened. I suggest your bank take a step back and look at this as you would if the account relationship were proposed today. First, do you want to do it? Second, what fee schedule would make it profitable?

Thank you Ken for the information. I appreciate everyones responses.