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#2213144 - 05/08/19 07:41 PM Notice of ATM/Night Deposit Facility User Precauti
Patricia Offline
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Joined: Mar 2011
Posts: 327
Kansas
Can the Notice of ATM/Night Deposit Facility User Precautions be a separate disclosure or does it need to be included in the Reg E initial disclosure?

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#2213168 - 05/09/19 12:02 PM Re: Notice of ATM/Night Deposit Facility User Precauti Patricia
Adam Witmer Online
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Joined: Sep 2010
Posts: 2,562
Well, I'm not sure what exactly you include in that notice. If any of the items required to be disclosed in 1005.7 are included in that notice (and not also included elsewhere in your EFT disclosure), then it should be included. While night deposits are not EFTs (and thus not needed in the EFT disclosure), certain ATM disclosures would need to be in your EFT disclosure (such as ATM limits, fees etc.)
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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.
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#2213170 - 05/09/19 01:12 PM Re: Notice of ATM/Night Deposit Facility User Precauti Patricia
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 76,928
Galveston, TX
This notice would be based on State law. It is in Texas.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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