We are not aware of any Illinois or federal laws that would prohibit a national bank from establishing a mobile ATM (or a state bank, for that matter). The IDFPR has stated in an Interpretive Letter that mobile ATMs are permitted under Illinois law (Interpretive Letter 93-32 (December 22, 1993)). In addition, a mobile ATM is not subject to any OCC notice or application requirements — under the OCC regulations, a mobile ATM “is not a ‘branch’ . . . and is not subject to state geographic or operational restrictions or licensing laws.” 12 CFR 7.4003.
We are considering offering an ATM that can move around to wherever local events are happening. Are there any banking regulations that would prevent us from using a mobile ATM?
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