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If we don’t accept deposits at an ATM location, does the Regulation CC disclosure requirement apply? – IBA Compliance Connection

IBA Compliance Connection

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If we don’t accept deposits at an ATM location, does the Regulation CC disclosure requirement apply?

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We do not believe that the regulation requires the funds availability notice at ATMs that do not accept deposits. The regulation states that the notice must be provided “at each ATM location.” However, the regulation defines “ATM” as “an electronic device at which a natural person may make deposits to an account by cash or check and perform other account transactions.” 12 CFR 229.2(c). Therefore, if an ATM does not accept deposits, it would not fall under the definition of ATM for purposes of Regulation CC. Also note that the Official Staff Commentary to the rule states that the notice is required “on all ATMs at which deposits can be made to accounts at the depositary bank.” Comment 1, 12 CFR 229.18(c).