IBA Compliance Connection

Your go to source for compliance!

Under Illinois law, does the owner of a privately owned ATM need to be licensed? We have customers that own ATMs, and they claim that they are not required to hold a license because another entity processes the ATM transactions.

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No, Illinois law does not require a license, but it does require the individual or non-bank entity that owns or establishes the ATM to register it with the IDFPR.

For resources related to our guidance, please see:

  • Illinois Electronic Fund Transfer Act, 205 ILCS 616/30(B) (“A person other than a financial institution or an affiliate of a financial institution may establish or own, in whole or in part, a cash-dispensing terminal . . . provided that the person establishing or owning the terminal shall file a notice of the establishment or ownership of a terminal with [the IDFPR].”