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Are banks in Illinois required to get state approval before opening a “freestanding” ATM? We’re thinking about placing an ATM somewhere that would not be attached to a branch location. A third party vendor would service the ATM. – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Are banks in Illinois required to get state approval before opening a “freestanding” ATM? We’re thinking about placing an ATM somewhere that would not be attached to a branch location. A third party vendor would service the ATM.

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We do not believe that you need to get any prior approval from the state before opening an ATM that is not attached to any branches or other premises of your institution. The IDFPR’s application and notice requirements apply only when you are opening new premises that fall under the Illinois Banking Act’s definition of “branch.” See Interpretive Letter 91-21 (September 4, 1991). The definition of “branch” specifically excludes ATMs (referred to as “electronic terminals”) from the definition. 205 ILCS 5/2.