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We make all cash deposits at ATMs available immediately. Since we do not distinguish between deposits at proprietary and nonproprietary ATMs, do we need to disclose a list of locations for our proprietary ATMs in our Regulation CC disclosure? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We make all cash deposits at ATMs available immediately. Since we do not distinguish between deposits at proprietary and nonproprietary ATMs, do we need to disclose a list of locations for our proprietary ATMs in our Regulation CC disclosure?

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No. Regulation CC requires you to disclose a list of the locations for your proprietary ATMs only if you delay the availability of cash deposits made at nonproprietary ATMs.

For resources related to our guidance, please see:

  • Regulation CC, 12 CFR 229.16(b)(5) (“The specific availability policy disclosure shall contain the following, as applicable . . . (5) A description of how the customer can differentiate between a proprietary and a nonproprietary ATM, if the bank makes funds from deposits at nonproprietary ATMs available for withdrawal later than funds from deposits at proprietary ATMs.”)