We have closed an ATM that was not being used that often - we did the math. As a courtesy we gave 30 days notice. DO we have to include this is the CRA Public FIle that we closed it?

Was this ATM on-site (attached to a branch) or was this ATM in a remote location? We consider a remote ATM a form alternative delivery and would include in our branch opening and closing list in the bank's public file. As for documenting the reason for the closing, include in your file the analysis used to make the decision (transaction volume, etc.) If it is located in a LMI census tract, document your case even more - (distance to closest ATM and branch, how if any will removing the ATM affect access to bank services, etc.).

Your main concern, if this is a free standing ATM not at a branch is the effect on banking in that community, particularly if a low/mod or distressed/underserved community.

The thought process discussed in this thread would apply.

http://www.bankersonline.com/forum/ubbth...rue#Post1640880

If this is the little used ATM you mentioned elsewhere this should be a quick analysis as the is not much demand for the service provided.

Kathleen,

Would you include in the List of Openings and Closings in the Public File?

Not unless it was deposit taking. Or perhaps in a separate section, but I would acknowledge the action and be prepared to discuss it.

The main thing is to acknowledge the impact removing access to banking services has. If little impact, great!