We are in the process of updating all of our ATMs. While working through the paperwork for how we want different things set up, the discussion of what balances are provided to the customer came up. Currently we only provide a current balance (does not include any pending items) on the printed receipt. However, when doing a balance inquiry, the current balance and available balance are provided on the screen of the ATM. The available balance includes a balance from another account if the customer is enrolled in our Overdraft Protection (transfer from another checking or savings account) and also includes any pending debit card transactions. We currently have a notice on our online banking/mobile banking stating the Overdraft Protection balance is included, but it does not state that the balance includes any pending transactions. I just realized that there is not a notice on the ATM screen stating any of this. We are working to get this corrected.

My question is: should we also state that the available balance includes any pending debit card transactions? Instead of just saying it includes the Overdraft Protection balance from another account? Also - does this notice need to be on the actual screen with the balances or could it be a sticker we create and add to the ATM? The reason I ask this is because I may get some pushback to update our current machines when we will be replacing them in a matter of months. I have also suggested just removing the available balance, however, I'm not sure that will fly either.

My biggest concern is that we have examiners coming in during October for an exam. So I want to get this correct somehow.

Regulation DD, section 1030.11(c) and Official Interpretation 11(c)-4.

The balance(s) can be provided on the screen, with the notice or on a paper "receipt" with the notice. There's not stated option to put the notice on a sticker on the ATM or elsewhere (such as in list of notices on the ATM surround, etc.). The concept calls for the notice to be with the balance(s).

You could add "net of pending debit card transactions" or words to that effect. But the point of the requirement is to note that the "puffed" balance includes funds from other than the account itself.

The other issue is that while your bank's ATMs may support that language, there is no guarantee that it while translate to every ATM in the world as other machines may not pick up that verbiage from your processor. When Reg DD was updated in 2010, it was basically crafted in such a way to tell the industry to knock off comingling puffed up balances with the actual amount that a consumer has on deposit.

Thank you John & Brian. So if we were to remove the option of receiving their balance on the screen and only offer it on paper (by receipt). And the only balance offered was the current balance (after any items have actually posted to the account). Would that be sufficient?

The thrust of the rule that requires the "explainer" text is to make certain the cardholder understands that that "puffed" balance (my term) includes other funds besides the balance in the target account. If you don't provide the "puffed" balance, you don't need the extra language. And it's not dependent upon whether the customer has auto-trans set to cover and OD in the checking account, or has opted in to OD service for ATM transactions, or has an OD line of credit.

Thanks John! I appreciate your explanations. We are working on getting all extra balances (the puffed balances) removed. I would prefer to continue providing an available balance that includes debit card holds and deposit holds along with the current balance. It all comes down to what changes we can make in our Core system. We are trying to get the balances provided by the ATM, online/mobile banking, text/email alerts and our Bank by Phone system to all be consistent. Right now they are not....

As I said, I believe it comes down to what/how we have balances set up in our Core. Hopefully we can get this all figured out and get some consistency in place.

I appreciate all the help I continue to receive on these forums! I seem to have a lot of questions! LOL

Along the ATM receipts, what is required on the receipt if all they are doing is depositing a check VIA ATM/ITM? 1005.9 talks about providing a receipt when a customer initiates an EFT. Does this cover deposit only via ATMs?

Thanks!