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#2215123 - 06/06/19 03:40 PM Does Reg E applicability to privately owned ATMs
Newbanker Offline
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Joined: Aug 2015
Posts: 51
Does Reg E apply to privately owned ATMs?

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eBanking / Technology
#2215126 - 06/06/19 03:45 PM Re: Does Reg E applicability to privately owned ATMs Newbanker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
What does an ATM - private or otherwise - have to do with Regulation E? The debit/ATM card is the access device.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2215129 - 06/06/19 03:56 PM Re: Does Reg E applicability to privately owned ATMs Newbanker
Newbanker Offline
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Joined: Aug 2015
Posts: 51
Since the coverage of Reg E states that it generally applies to a financial institutions. And Reg E makes reference to a "financial institution" I was wondering if compliance with Reg E is shifted to the FI instead of the private ATM company?

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#2215135 - 06/06/19 04:15 PM Re: Does Reg E applicability to privately owned ATMs Newbanker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
The customer uses your debit card - it does not matter where they use it - the Regulation E compliance burden is on the bank.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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