We have a few customers (bars, etc) that have ATMs on-site. In some instances, the customer contracts with an ATM provider that, provides, funds and services the ATM. Our customer has no responsibility except to collect a per transaction fee which is provided montlhly via check. I am curious what other banks are doing in terms of monitoring when these types of ATMs. Are you requiring periodic statements, descriptions of loading processes, etc. we currently do, but are finding it difficult to get the info. In most cases, customers don't want to be bothered requesting the info and some ATM providers are unresponsive if we contact them directly.

Thanks

I don't think it's reasonable to require that information if you are satisfied that your customer has no involvement in the operation of the ATM beyond collecting what amounts to rent for the space. If the customer doesn't service the machine or replenish the cash, the only other possible cash involvement would be that your customer might receive a payment for his goods or services in cash that was withdrawn from the ATM. That would be the case if the ATM were across the street at a bank branch.

That is my thought and what we were doing originally. We made sure we got a copy of the agreement and verified corporate registration of the co via corporation search. Our internal auditor indicated we should be requesting more info.

I am thinking we might be the only bank doing this...

Ask your internal auditor why you should be requesting this information. If your customer has no involvement with the operation or servicing of the ATM, then the Private ATM responsibility falls upon the bank that has the account of the ATM operator.

Privately owned ATM's (the Canadians call them "white" ATMs) are an issue. However, your auditor is apparently assuming a "canned" response is appropriate. Your response, determining ownership, servicing, etc. is what is necessary. It's about analyzing the risks, not about acquiring pieces of paper.

I am new to the area of privately owned ATMs and we have just opened an account for one last week. I have printed the ATM checklist I found referenced here on BOL and it has been most helpful! My question is what is the ongoing monitoring that should be happening with these accounts? Do you review them monthly? Quarterly? Or does an annual overview suffice? Thanks!

We have a customer that has an ATM on site, which is owner operated. They participate in other activities that we consider to be high risk, so the accounts are monitored monthly. It would probably be determined from a risk assessment of the customer.

Since we have just a handful of privately owned ATMs, monitoring of ATM accounts has never been addressed. In looking at a couple of the accounts, one customer has auto deposits coming into the account and routinely makes similar withdrawals in straps of twenties to replenish it. The other customer account I looked at had similar auto deposits but then would transfer all of the funds save a thousand or so to their payroll account. They then come in person every few weeks to get just a couple straps of twenties and other miscellaneous denominations from their main corporate account - sometimes indicating its for the ATM. They are a nightclub if it makes a difference. Are both acceptable? Any insight or observations would be greatly appreciated!