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No ATM Fee: Do we need any disclosures?

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Question: 
We don't charge an ATM fee Do we still have to post the disclosure on the ATM machine or put it on the printout?
Answer: 

Under the recent amendments to Regulation E, there are two new changes. One is a change to the initial Reg E disclosures you make to your customers. Under that change, the Model Language suggests using the following new wording:

When you use an ATM not owned by us, you may be charged a fee by the ATM operator [or any network used] (and you may be charged a fee for a balance inquiry even if you do not complete a fund transfer).

The second disclosure is one made by ATM operators. If an ATM operator imposes a fee on a consumer for initiating an EFT or a balance inquiry, it must first provide notice that a fee will be imposed for providing the EFT or balance inquiry and disclose the amount of the fee. If the fee would be imposed only for specific types of transactions, such as cash withdrawals, but not for balance inquiries, the notice may be a general statement that a fee will be imposed for providing EFT services or may specify the type of EFT for which the fee is imposed. The notice must be provided two ways.

If your institution, in operating ATMs, is not imposing a fee for initiating an EFT or a balance inquiry, you need not supply the second disclosure.

First published on BankersOnline.com 5/07/01

First published on 05/07/2001

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