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Does a Cash ATM Deposit Fall Under Reg E?

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Question: 
Does a cash ATM deposit fall under Reg E?
Answer: 

Yes, see the definition of an electronic funds transfer in 1005.3(b)(1)(iii) which includes debits and credits involving automated teller machines.

(b) Electronic fund transfer. (1) Definition. The term “electronic fund transfer” means any transfer of funds that is initiated through an electronic terminal, telephone, computer, or magnetic tape for the purpose of ordering, instructing, or authorizing a financial institution to debit or credit a consumer's account. The term includes, but is not limited to:

(i) Point-of-sale transfers;

(ii) Automated teller machine transfers;

(iii) Direct deposits or withdrawals of funds;

(iv) Transfers initiated by telephone; and

(v) Transfers resulting from debit card transactions, whether or not initiated through an electronic terminal.

First published on 06/21/2020

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