While cryptocurrencies and digital payments apps are all the buzz lately, the need for access to quick hard cash seems to never go away. Among the many great services that credit union’s provide, a proprietary or shared-branch ATM still remains one of the most convenient methods to grant members (and non-members) 24-hour direct access to account funds. Wherever you are in the world, one can simply slide in a card, enter a pin, and viola, out comes cash! So, what should we include on these magic money devices?
The notices or signage that credit unions may need depend in large part on the ATM’s capabilities. Since state laws may also provide additional varying requirements, here is a non-inclusive list:
Regulation E Notice. Section 1005.16(c) requires ATM operators to include a notice on the screen or on paper disclosing any fee that may be imposed for transfers or balance inquiries. Credit unions are only permitted to impose such fees if the consumer is provided notice of the fee amount and elects to continue the transaction or inquiry after receiving this notice. Although notice is only required for non-account holding consumers, this distinction may be difficult to execute on a practical level. Thus, credit unions often make the business decision to provide this notice on the screen for all users.
Regulation CC Notices. Reg CC requires a notice to be posted or provided which explains that funds deposited in the ATM may not be available for immediate withdrawal. When it comes to off-premises ATMs in which funds are removed two times or less per week, credit unions are required to also disclose the days on which deposits made at the ATM will be considered received. See, 12 CFR 229.18(c-d).
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