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#1936129 - 06/27/14 03:33 PM Entities with FI-Branded ATMs on Premise
BSA Aficionado Offline
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Joined: Feb 2013
Posts: 98
If an FI establishes a banking relationship with an entity (e.g., major pharmacy or convenience store) who has FI branded-ATMs on premise, am I correct in my interpretation that due diligence need not be performed on those ATMs since they are not "private?"

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#1936136 - 06/27/14 03:43 PM Re: Entities with FI-Branded ATMs on Premise BSA Aficionado
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Correct.
That would not be a Private ATM.

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#1936167 - 06/27/14 04:18 PM Re: Entities with FI-Branded ATMs on Premise BSA Aficionado
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
The key in my mind is 'who is responsible for replenishing the cash in the ATM?' Your due diligence should focus on your customer if they replenish. If they just rent space then they are not considered the owner of the ATM.

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#1936174 - 06/27/14 04:24 PM Re: Entities with FI-Branded ATMs on Premise devsfan
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
This instance may be a little less fact sensitive than normal, the ATM is branded as belonging to a bank. As such, it's simply not a private ATM and triggers no due diligence responsibility on the part of the convenience store's bank beyond, perhaps, simply noting its presence and its owner.
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