ITMs & Reg E

We are going to be replacing all of our ATM machines with ITMs within the year. I'm trying to get straight in my head, which transactions will be considered EFT and which will not. If the customer scans their debit card to initiate a transaction, then would that be considered an EFT? What if they scan their debit card and then they request the help of a virtual teller? Would it be an EFT? If the customer simply walks up to an ITM and immediately requests a virtual teller and scans an ID, I would assume that would not be considered an EFT, even though the transaction is being completed at a terminal? I'm starting to really confuse myself and any guidance would be appreciated!

Thanks so much.

Regulation E includes one comment paragraph that helps separate EFTs subject to the regulation from employee-assisted transactions, which generally are not covered.

Comment 2(h)-3:

Thank you so much John! This answers my question. And, I promise I looked through Reg E yesterday and never did see this paragraph! I will be going back and finding it today though.

I appreciate your help!

With regards to ITMs and teller assisted transactions would these be considered ATM transactions for overdraft opt in purposes under Reg E or since they are teller operated would they be they be excluded as from this part of Reg E as well?

It seems they would be exempt since they would not be covered by Reg E but would the notice not be confusing to the customer if they opt to not authorize and pay overdrafts for ATM transactions?