No, we do not believe that installing non-deposit taking ATMs in another state would alter your bank’s required CRA assessment areas. Your CRA assessment areas must include your bank’s main office, its branches, and its deposit-taking ATMs (as well as the surrounding geographies in which your bank has originated or purchased a substantial portion of its loans). Placing ATMs that do not take deposits should not result in an expansion of your bank’s CRA assessment areas, absent other bank activities in the same geographical area (such as loan originations or purchases).

For resources related to our guidance, please see:

• Regulation BB, 12 CFR 345.41(c)  (“The assessment area(s) for a bank other than a wholesale or limited purpose bank must: . . . (2) Include the geographies in which the bank has its main office, its branches, and its deposit-taking ATMs, as well as the surrounding geographies in which the bank has originated or purchased a substantial portion of its loans (including home mortgage loans, small business and small farm loans, and any other loans the bank chooses, such as those consumer loans on which the bank elects to have its performance assessed).”)