We believe that you can rely on the amendment to the federal law removing the ATM placard requirement. The Illinois Electronic Fund Transfer Act (EFTA) does require that banks post a fee notice on a sign on their ATMs (in addition to the onscreen notice). 205 ILCS 616/5038 Ill. Adm. Code 315.410. However, the law also provides that compliance with the federal EFTA requirements will be deemed to be compliance with the Illinois requirements. 205 ILCS 616/55IDFPR Interpretive Letter 06-01. Because the federal law no longer requires a physical fee notice, we believe that a bank would be deemed to be in compliance in Illinois law even if its ATMs do not have the physical fee notice.