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#2176935 - 05/07/18 03:21 PM ATM and Reg DD
cstrauss Offline
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cstrauss
Joined: Jun 2015
Posts: 21
Stamford, CT
Do the exemptions for indoor signs under Reg DD (12 CFR 1030.8(e)) apply to ads displayed on lobby/on premise ATMs? I know 1030.11 (OD advertising) excludes ATMs from the indoor sign exemptions. Is a drive up ATM a billboard/outdoor media under 1030.8(e)?

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#2177091 - 05/08/18 12:21 PM Re: ATM and Reg DD cstrauss
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
First, my answer is going to assume you are referencing ads displayed on the ATM screen rather than an ad on the side/top of the physical ATM.

Unfortunately, the rules don't clearly address ATM screens and I think you may even find mixed opinions regarding what is correct. Therefore, the conservative approach would be to only include fully compliance ads on your ATM screens. That said, I could see an argument for using the indoor sign exemption if the ATM is physically located inside your branch - if it is outside of the physical branch (such in a drive through lane), it would not clearly not qualify IMHO.

From the commentary:
"1. General. Indoor signs include advertisements displayed on computer screens, banners, preprinted posters, and chalk or peg boards. Any advertisement inside the premises that can be retained by a consumer (such as a brochure or a printout from a computer) is not an indoor sign."
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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