Interactive teller machines and regulatory requirements

Credit unions are known for serving their communities and operating in a lean way to ensure members receive cost-saving benefits in the forms of lower loan rates, higher dividends and additional services. This is why many credit unions are now turning to interactive or video teller machines. These machines allow credit unions to provide members with a face-to-face experience via the interactive teller machine while reducing the costs of maintaining a branch.

While innovation has always moved fast, regulations are sometimes slower to catch up. This may leave credit unions wondering how to provide these services while complying with our current regulatory landscape. Depending on the service interactive teller machines provide, different regulatory requirements may come into play. Let’s review a few different requirements.

Regulation E Consumer Protections

Regulation E provides certain protections to members who conduct electronic funds transfers (EFT) at electronic terminals. An electronic terminal is considered to be “any electronic device, other than a telephone operated by a [member], through which a [member] may initiate an [EFT].” 12 C.F.R. § 1005.2(h). This includes point-of-sale terminals, ATMs and cash dispensing machines. The question becomes, is an interactive teller machine or similar technology considered to be an electronic terminal?


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