We believe that Illinois banks can rely on the amendment to the federal law removing the ATM placard requirement. The Illinois Electronic Fund Transfer Act (EFTA) does require that Illinois 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.