We are looking at investing in ITMs. Would anyone who went live with one, or is knowledgeable, share what regulations they applied as well as any advice on implementation?

Also, the machine functions as an ATM or a interactive teller, so depending on the time of day different functions are available (ie. deposits and loan payments can only be made while teller is online). So how do you disclose the appropriate signage.

Any input or risk considerations would be appreciated.

We created a sign with all out normal teller window and ATM disclosures on it. It fits on the face of the machine as the customer drives up they can see it.

We did the same. We rolled out 5 ITM's last year we had our machines wrapped with our branding that also included the cards that are accepted, availability of deposits and Member FDIC as part of the wrapping on the front of the machine. The funds availability disclosure is also on the home screen before you begin to interact with the live teller.

When a deposit is made through an ITM and the teller reviews the item at deposit, is it considered a deposit "made in person" under Reg CC, or would it still be considered an ATM/not in person deposit?

Anyone? My credit union is preparing to implement ITMs in the coming months, but I cannot locate much about how ITMs will fit within Funds Availability. The deposit isn't being made in a branch, but a teller is looking at the item at the time it is being deposited.
Thoughts?

Our ITMs are tellers, therefore we consider deposits made through the ITM as made in person.

Our ITM is run by a teller who reviews transactions and makes decisions to accept or reject transactions. We use the standard Funds Availability Policy for these transaction. Our ITM is an ATM when activated with the Debit Card and our EFT vendor is processing the transactions. We use the standard Funds Availability Policy for ATM deposits because we don't allow customers to deposit anywhere except our bank ATM's. We could have given longer availability, but have no reason to do so.

How do you handle hold notifications through the iTM if you consider deposits as made in person?

Mtngrrl, we are supposedly going to be able to print the hold notice on the ITM receipt.

I don't know why I didn't think of this sooner - in fact a co-worker mentioned it. We will just treat the ITM like a deposit in the drive thru, and the shortened Funds Availability disclaimer isn't required there. So we can just post the "Funds from your deposits may be delayed..." and then provide notice of hold on the receipt should we delay funds at the time its deposited.
Anyone disagree?