OK, Oklahoma bankers, I need some help! I was recently informed that if a business owner has a privately owned ATM they are required by state law to register that ATM with the State Banking Commission...annually by April 1.

I found the forms on the state banking website, but my question,is there a registration list or other database of already registered businesses/persons? I could not locate one.

Thanks!

There is no list on the Oklahoma State Banking Department's website, so you would need to call them to get a list. Your customer should be able to provide you with a copy of his registration to show that he is in compliance.

So, what if one of my customers flat REFUSES to provide me a copy of their certificate?

Either call the State Banking Commission and ask for the current registration (no right of privacy would be violated) or close the account.

I would be doing the latter suggestion rather than the former. An account at your bank is a privilege rather than a right and you dictate what the customer must provide to have an account, not the other way around.

Agreed. Evidence of required registration is no different than any other CIP required document. Besides, how are you going to explain to your examiner that you don't have it and continue to let him do business through your bank.

Aside: let me have three guesses as to the customer, and the first two won't count........

We just recently became aware of this requirement.

The rules refer to "installation" of ATM.

Should we take this literally and require documentation of the registration from customers who have an ATM on the premises but do not own the ATM? This is a fairly common scenario in OK.

What about ATMs that are owned by the bank and placed at a customer's place of business?

Following

You are following a post that has not been updated in 7 years?

Plus, the department banking now posts the list: https://oklahoma.gov/banking/institutions-lists/atms-privately-owned.html

I did not pay attention to the date of the post but I still needed the answer - however I did already find the OSBD list. Thank you