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Funds Availability Notice on ATM Deposit Envelopes

Question: 
Does the funds availability notice have to be on ATM deposit envelopes?
Answer: 

by Ken Golliher: The ATM related disclosure requirement is:

c) Automated teller machines. (1) A depositary bank shall post or provide a notice at each ATM location that funds deposited in the ATM may not be available for immediate withdrawal.

As there is no requirement to have envelopes at an ATM, no compliant disclosure could be made there. It doesn't hurt anything to put it on the envelope, but it doesn't hurt anything to leave it off either. The disclosure is generally made on the screen or on the machine itself.

Answer: 

by John Burnett: Under the Commentary to Regulation CC, Comment 18(c)-2 allows the notice that Ken's described to be put on deposit envelopes in lieu of putting it on the machine or screen. The notice isn't required at machines that don't take deposits.

Of course, as more banks upgrade to machines that don't take envelopes, the notice will need to move back to the screen or machine.

Answer: 

by Randy Carey: Of course the new ATMs don't accept checks for deposit, they scan the checks and the images are deposited so they would not be subject to Regulation CC anyway.

Answer: 

by John Burnett: Just to round out this discussion, what Randy points out is true, at least currently, unless the ATM owner only uses the images internally and removes the checks for clearing and presentment. That's not a terribly efficient use of the imaging technology, but I am aware of a few banks that have taken that half-step toward RDC at the ATM.

First published on 04/21/2014

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