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#2266973 - 02/28/22 04:38 PM ITMs & Reg E
Bankwoman1 Offline
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Joined: Dec 2015
Posts: 869
Midwest
We are going to be replacing all of our ATM machines with ITMs within the year. I'm trying to get straight in my head, which transactions will be considered EFT and which will not. If the customer scans their debit card to initiate a transaction, then would that be considered an EFT? What if they scan their debit card and then they request the help of a virtual teller? Would it be an EFT? If the customer simply walks up to an ITM and immediately requests a virtual teller and scans an ID, I would assume that would not be considered an EFT, even though the transaction is being completed at a terminal? I'm starting to really confuse myself and any guidance would be appreciated!

Thanks so much.

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eBanking / Technology
#2267028 - 03/01/22 03:06 PM Re: ITMs & Reg E Bankwoman1
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
Regulation E includes one comment paragraph that helps separate EFTs subject to the regulation from employee-assisted transactions, which generally are not covered.

Comment 2(h)-3:
Quote
3. Teller-operated terminals. A terminal or other computer equipment operated by an employee of a financial institution is not an electronic terminal for purposes of the regulation. However, transfers initiated at such terminals by means of a consumer's access device (using the consumer's PIN, for example) are EFTs and are subject to other requirements of the regulation. If an access device is used only for identification purposes or for determining the account balance, the transfers are not EFTs for purposes of the regulation.
Last edited by John Burnett; 03/01/22 03:09 PM.
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#2267029 - 03/01/22 03:09 PM Re: ITMs & Reg E John Burnett
Bankwoman1 Offline
Platinum Poster
Joined: Dec 2015
Posts: 869
Midwest
Thank you so much John! This answers my question. And, I promise I looked through Reg E yesterday and never did see this paragraph! I will be going back and finding it today though.

I appreciate your help! smile

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