What are the ATM (sticker) disclosure requirements? I recall there was one about fees some time ago however that has been added to most screens as a disclosure before continuing the transaction, but I feel as though there was another required?

Regulation E section 1005.16 used to require two notices-- the first was a note on or at the machine that the operator of the ATM or ATM network will impose a fee (surcharge). The second was a notice on the screen (or printed on a receipt) during the transaction that informed the card holder of the surcharge and its amount. This notice also had to tell the card holder to cancel out of the transaction to avoid the fee.

The "on or at" notice (the first one in the paragraph above) was legislated out of the EFT Act and dropped from Reg E a few years ago because (1) it was redundant and (2) some opportunists (including one attorney) were removing the disclosures and threatening ATM operators with lawsuits.

Some states haven't yet gotten around to getting rid of their parallel "on or at" notice requirement for surcharges. Check you state's rules to see if you still have to have one up.

States might have other notice or signage requirements.

And of course, there may be ATM network requirements for displaying their logos.

I'm deliberately omitting the Reg CC notice for ATMs that accept consumer deposits because most banks put the notice on their screens during the deposit screens sequence.

If deposits are accepted at our ATM's, would the Reg CC Model notice disclosures 19 & 20 be required on non-proprietary machines?