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#2243376 - 09/30/20 06:20 PM ATM Deposits
Bankwoman1 Offline
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Midwest
Question on how we handle ATM deposits. Currently, when a deposit is made in an ATM (proprietary) a hold is put on the funds until the next business day and $200 is made available immediately. Our terms and conditions state that funds from a cash or check deposit are made available on the first business day after the day we receive the deposit (this is for all deposits). We have a cut off time of 12:00 pm for our ATM machines and this is stated in our T&C's. My question is this - do we need to make that $200 available immediately when an ATM deposit is made? I feel like somewhere along the way we got confused with Reg CC holds and what our T&C's actually state. We actually make deposits made in person to a teller available immediately unless it is decided a Reg CC hold is needed. However, our system is set up to automatically hold the funds from an ATM deposit until the next business day, which makes perfect sense to me since we would want to have a chance to pull the deposits each day and view the deposit. We've had too many empty envelope incidents in the past.

So, couldn't we actually hold the full amount of the deposit until the next business day and then once the check is pulled from the ATM decide if a Reg CC hold is needed? I feel like we are hurting ourselves by making that $200 available.

I hope this makes sense!

Thanks!

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#2243398 - 09/30/20 08:05 PM Re: ATM Deposits Bankwoman1
BrianC Offline
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BrianC
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Illinois
You can always make more funds available than the regulation requires The commentary to 229.2(a)(a) says the following on ATM deposits:

AA. 229.2(aa) Proprietary ATM
All deposits at nonproprietary ATMs are treated as deposits of nonlocal checks, and deposits at proprietary ATMs generally are treated as deposits at banking offices.

Your mandatory proprietary ATM availability requirements are to treat ATM deposits the same as you would if the person walked into a branch and handed the check to a teller. (Except for the mandatory next-day checks that have an "in-person requirement in 229.10(c)(ii) - (v)
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#2245237 - 11/06/20 06:26 PM Re: ATM Deposits BrianC
Bankwoman1 Offline
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Midwest
So...finally getting back to this Brian. Let's say we have a customer deposit a check in a proprietary ATM on Friday afternoon (after we have balanced the ATM). Currently our ATM is holding all but $200 of the deposit amount. This hold is falling off the next day (Saturday). 1. Could we set it up to hold the this amount until the next business day - or does the hold have to fall off on the next calendar day? 2. If the deposit is a next day item (not a Treasury Check) and we balance the ATM the following Monday - since the deposit wasn't made in person - could we then put a Reg CC case by case hold on the funds if we deemed it necessary? And would the date of deposit be considered Friday?

I don't know why this is so confusing to me.

Thanks!
Last edited by Bankwoman1; 11/06/20 06:42 PM.
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#2268859 - 04/08/22 07:06 PM Re: ATM Deposits Bankwoman1
Bankwoman1 Offline
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Midwest
I know this post is from 11/2020, but I'm wondering if anyone could help me out with the last post I made to the thread. for some reason I get really confused as to how ATM deposits at proprietary ATMs have to be handled.

Thanks!

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#2268862 - 04/08/22 07:18 PM Re: ATM Deposits Bankwoman1
BrianC Offline
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Illinois
Deposits at ATMs are handled the same way as if a check is handed to a teller at the branch.

If your teller accepts a check for deposit after cutoff on Friday afternoon, when does your policy say that will be made available? You would follow the same schedule for deposits made to an ATM after your disclosed ATM cutoff time.
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#2268865 - 04/08/22 07:31 PM Re: ATM Deposits BrianC
Bankwoman1 Offline
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Midwest
Ok. So, our T&Cs state a deposit will be made available on the next business day. If a customer comes into the branch and makes a deposit, we currently make it available immediately (because that is how our system is set up) unless we decide to place a Reg CC hold on the item.

Our T&Cs also state that if a deposit is made at our ATM before noon, then that day will be considered the day of deposit. If it is made after 12:00 then the following business day is the day of deposit.

So my question is this: If a customer comes in at 10:00 am and makes a deposit to the ATM, Can the full amount of the deposit be held until we open the ATM and verify the items later that same day? Do any funds have to be made available prior to us pulling the deposits?

AND

if a deposit is made after the 12:00 (noon) cut-off (for ATM only) can the full amount of the deposit be held until the following business day when we open the ATM and pull the deposit? Do we need to make any funds available prior to pulling the deposits?

Are we breaking any rules by making funds available immediately when made at a teller window, but holding funds until the next day when made at an ATM?

I don't mean to be a pain and I hope I don't sound stupid.....I'm struggling with making sure we are doing things correctly. smile

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#2268866 - 04/08/22 08:59 PM Re: ATM Deposits Bankwoman1
rlcarey Online
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Galveston, TX
As Brian said, a deposit at the ATM is just like a deposit with a teller. The deposit would be treated no different than you would treat a deposit if you had a cut-off time at your teller line. If your availability policy says that you make funds available the next business day, I am not sure where you think the problem might be.

The question regarding whether your policy is really your policy is another question. I think in this day and age that is pretty common. Regulation CC is terribly outdated.
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#2268920 - 04/11/22 07:42 PM Re: ATM Deposits Bankwoman1
Bankwoman1 Offline
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Joined: Dec 2015
Posts: 858
Midwest
Thank you Randy! You and Brian are always a big help.

I appreciate it.

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