IBA Compliance Connection

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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?

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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.”)