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Is there any law or regulation requiring us to post our name on all ATMs? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Is there any law or regulation requiring us to post our name on all ATMs?

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We do not believe that you are required to post your name on your ATMs. Regulation E does not require that banks post their names on ATMs and requires only that they disclose any fees charged. See 12 CFR 1005.1612 CFR 1005.9. The Illinois Electronic Fund Transfer Act does require that banks post a fee notice on their ATMs that includes, among other information, the name of the bank operating the terminal. 205 ILCS 616/5038 Ill. Adm. Code 315.410. However, it also provides that compliance with federal law, including the Regulation E requirements described above, will be deemed to be compliance with the Illinois requirements. 205 ILCS 616/55IDFPR Interpretive Letter 06-01.