ATM Balance Information

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Question:

Our Marketing Department recently surveyed our customers and learned that many of them want to be able to get their available balance at an ATM. When Marketing suggested to our EFT Department that we make the change to provide that information, they ran into a brick wall. The folks in EFT say it isn't allowed. Are they telling it like it is, or just reluctant to change?

Answer:

It's too bad your EFT staff didn't explain themselves, because it could have cleared the air quickly. I'll assume that your institution has a Courtesy Overdraft Program (often called an Overdraft Protection Program, or ODP). That usually makes a participant's "available balance" greater than the participant's ledger balance by the amount of available ODP protection. Reg DD (Truth in Savings) requires, in section 230.11(b), that when an ATM displays the amount of available ODP coverage, or any balance that includes the coverage amount ("triggering balance information"), the account-holding bank is considered to be promoting the payment of overdrafts. That triggers a requirement that the ATM screen that reflects that amount must also include (1) the fee or fees imposed by the account-holding bank for the payment of each overdraft (that includes ALL fees resulting from the overdraft); and (2) the time period by which the consumer must cover or repay any overdraft.

Your bank may be able to make those disclosures on its own ATMs if it displays the "triggering balance information." However, given current ATM network capabilities, your bank cannot display those disclosures on an ATM screen that you don't control. For that very reason, the STAR network (and presumably others) banned the sending of "triggering balance information" to the STAR network for display at network ATMs. Some institutions are able to appropriately disclose an ODP-padded balance and the required disclosures on its own ATMs, and send the "unpadded" balance to network machines. Other institutions are only able to provide one balance to all machines. The latter group would not be able to display ODP-padded balances on any machine, including their own.

First published on BankersOnline.com 04/16/07