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#544202 - 05/05/06 05:21 PM ATM Disclosures
waterlover Offline
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Joined: Aug 2004
Posts: 14
PA
We are opening our first ATM soon. I wondered where I could get an overview of all the disclosures that are required for ATMs. Anyone know?

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Operations Compliance
#544203 - 05/05/06 08:45 PM Re: ATM Disclosures
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Besides your required network bugs (not required by regulations, but by contract), you need to have the Reg. CC funds availability short notice for ATMs (if you will accept deposits there). If you will charge customers of other banks a fee for use of your ATM, there are two notices required under Reg. E section 205.16. The first is on the machine, telling the world that you will (or may, if you selectively charge) impose a fee on customers of other banks for transfers or withdrawals (and balance inquiries, if you will). The second is a notice on the screen that tells them the amount of the charge to be imposed if they proceed, and provides them an instruction on how to cancel the transaction and avoid the fee.

You do not have to have a member FDIC message or sign.

In the unlikely event that you will gather any NPI from non customers, you need a Reg. P notice. I have never seen an ATM with this notice, however.

Anything else, I think, is state law.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#544204 - 05/08/06 02:35 PM Re: ATM Disclosures
waterlover Offline
New Poster
Joined: Aug 2004
Posts: 14
PA
Thanks a bunch for the help!

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