I realize I am late to this game, but am working on our private ATM owners. I am looking for a sample letter that we can make our initial request for contracts, etc. Anyone have a sample they are willing to share?

We didn't send a formal letter, we did the old fashioned way and picked up the phone to ask.

It has come to our attention that you may have an ATM located at your business location. Federal regulations require Banks that maintain accounts for those with Privately Owned ATM’s on-site to conduct additional due diligence and obtain documentation for its records (the Bank Secrecy Act and the USA PATRIOT ACT)

If the ATM located on-site is not owned, operated and serviced by you and you only lease space to a third party for placement of the ATM, we will need of a copy of the lease agreement with this third party reflecting that relationship. We will not ask for any further documentation.

If you, as the business owner, actually own, operate and/or service and/or replenish the funds in the ATM, we need additional documentation for our files. The information we need is as follows:

 Copy of the ATM agreement with the sponsoring entity (purchase, sale or lease)
 Exact Location(s) of the ATM(s)
 Copy of the most recent bank statement in which the ATM activity is detailed (if this account is at XYZ Bank, please let us know, there is no need to provide a statement)
 Currency Servicing Arrangements
 How is the cash in the ATM being replenished (store proceeds, account withdrawals, armored car)
 How much and at what frequency is cash being put in the ATM
 What is the expected daily withdrawal activity for the ATM

Additionally, ATM’s are required by law to be registered with the Division of Banks and yours currently is not. Having a copy of your contract will help us help you decipher whose responsibility this is.

"Having a copy of your contract will help us help you decipher whose responsibility this is."

I would not be putting the bank in the position of providing an ATM operator legal advice.

I wasn't, often times the contract has helped us determine who should be the one registering it based on how the contract reads, that's all RLC.

I am just commenting on the specific content of the letter is all. I would be requesting proof of registration and leave it up to them to figure out who has to register it. You might make your own determination, but you are not going to help them do it.

Agreed. However, a lot of these small convenience stores are clueless. So, in obtaining the contracts, I've built myself up a network of contacts at the ISO's and I send them a letter telling them to register it and they do or send me evidence of our state form that they did. Leaving it up to some of the customers we'd be waiting forever as they have no idea what to do. And in my state PATMO's have been a hot button for years so I'm ok with going the extra mile if I can and it makes sense to do so to help the customer and ensure it's registered as required.