Looking for guidance on non-proprietary ATM deposits, their banking day of deposit, and funds availability. As I understand the regulation, the banking day of deposit for ATMs and off-premise facilities cannot have a banking day cut-off before 12:00PM. Funds from these ATMs must be available no later than the 5th business day following the banking day of deposit.

Our current daily cut-off for our debit cards/ATMs is after 12:00PM, and management would like to move up this cut-off to a time before 12:00PM. My understanding is that we cannot change this cut-off time earlier than 12:00PM, otherwise our banking day of deposit for ATM deposits would be out of compliance. I've been tasked with conducting further research.

In our current environment, a customer that makes a deposit before our daily card cut-off will have that deposit posted to their account at the end of the business day. We currently make funds available for withdrawal the next business day.

We cannot disclose a cut-off time prior to 12:00PM so I'm not sure how to disclose our banking day of deposit if our debit card file cuts before 12:00PM as well. Even though we have up to 5 business days for funds availability, we would still have to show the deposit posting to the customer's account on the banking day of deposit correct?

For example, if we disclosed an ATM cut-off of 3:00PM, customer makes an ATM deposit at 2:00PM today, but our debit card/ATM cut-off is at 10:00AM, we would still need to post the deposit to the account today? (Although we don't have to make those immediately available for withdrawal)

Am I missing something? Thanks in advance for any guidance you can provide.