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#1958199 - 08/29/14 04:05 PM Reg E Dispute-Deposit at Non-Proprietary ATM
SusanO Offline
New Poster
Joined: Mar 2011
Posts: 11
Our customer made a deposit of $400.00 in cash at a foreign ATM. Apparently, she thought she could make deposits to our bank at a foreign ATM-we have no arrangement with any institution for this. After the terminal had accepted the funds, $40.00 dispensed from the terminal and the customer was presented with a error message that read "Transaction Did not Complete". The customer went into the "foreign bank" and they informed her that she needed to dispute the transaction with her financial insitution to get the remaining $360.00. She contacted us a few hours later and we attempted to view the transaction. I contacted the foreign ATM branch where the deposit was made and they informed me that they are $360.00 over in cash in their deposits, but that we would need to send through an adjustment to get our customer's money back. Due to the transaction never completing, no communication was made to our bank in relation to the transaction. Therefore, we have no specifics to initiate an adjustment with our processor. Our processor has informed us that to process a "Good Faith Adjustment", they would need to have specific information related to the transaction to initiate the adjustment. My question is-what responsibility does the foreign bank have in researching overages at their ATM terminals? Normally this would not be an issue as we would have all of the detail to submit an adjustment, but this is a unique case. We provided our customer with provisional credit immediately. We are in the process of trying to get our money back.

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Operations Compliance
#1958204 - 08/29/14 04:15 PM Re: Reg E Dispute-Deposit at Non-Proprietary ATM SusanO
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,960
Illinois
Any responsibility that they have would be based on the operating rules of the ATM Network. Since you are the account holding institution, Reg E places the obligation to investigate on you.
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#1958232 - 08/29/14 05:13 PM Re: Reg E Dispute-Deposit at Non-Proprietary ATM BrianC
SusanO Offline
New Poster
Joined: Mar 2011
Posts: 11
Thanks for your help Brian. I did find the Rules for the ATM Network that this bank uses and they are required to initiate a deposit adjustment within 1 to 45 days of the date of deposit settlement.

11.3.1 Required Deposit Adjustments
A Terminal Participant must initiate a Deposit Correction in the event that
the deposited item:
(a) Represents a discrepancy of $250 or greater;
(b) Is a returned item of $500 or greater;
(c) Represents a discrepancy resulting in a credit to the Cardholder of
$10 or greater;

I will contact the network to see if this applies to foreign cardholders at a terminal as well.

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