If a bank wants to turn off the ability for individuals to use foreign ATMs due to the potential for fraud, would this be considered a non-proprietary ATM for the purpose of the standard language of the Reg. CC funds availability disclosure? I want to be clear on this so we can determine if we have to update our funds availability disclosure. Is there any regulatory cite I could be pointed to?

Thanks!

A non-proprietary ATM is one your bank doesn't own or service.

So that would mean that a foreign ATM would be considered the same as a non-proprietary ATM, correct? There are no separate rules for foreign ATMs? Based on this summation, we would have to include exclusionary language in our Reg. CC Funds Availability Disclosure for foreign ATMs, correct?

You may wish to clarify if you are speaking of ATMs located out of the country or ATMs that are not owned/operated by your FI. The industry utilizes the term Foriegn ATMs to mean those ATMS that are not owned/operated by you. It's been a confusing issue for many many years. Since you're discussing fraud, I'm thinking you are trying to block ATMs that are located outside of the US- with all the ATM skimming occuring in other countries, I'm wondering if that's what you are trying to get to.

Thanks for your response. Indeed, it was a clarification issue. I resolved the issue yesterday, and learned something new in the process.