We closed the drive-up ATM that we had at one of our branches. (We still have the walk-up ATM.) Does the closure of this ATM need to be reported in our CRA Public File under "Branches Opened or Closed"?

The definition of Branch is a staffed banking facility. However, an article from the St. Louis Fed stated, "changes to its retail branching structure, including deposit-accepting ATMs."

"St. Louis Fed stated, "changes to its retail branching structure, including deposit-accepting ATMs."

Where?

The 1996 amendment expressly stated that section 42 does not apply with respect to automated teller machines (Pub. L.104208, 110 Stat. 3009).

Thank you.

Article from the St. Louis Fed:

https://www.stlouisfed.org/en/publications/bridges/spring-2018/cra-profile

Interesting. That is not a requirement in Regulation BB nor is it covered in the FRB CRA exam procedures. I mean, there would be no harm, but it is not a requirement.

Thank you again!

Deposit-taking ATMS are a component of determining your assessment area and you could include them under your listing of services (At its option, a bank may include information regarding the availability of alternative systems for delivering retail banking services (e.g., ATMs, ATMs not owned or operated by or exclusively for the bank, banking by telephone or computer, loan production offices, and bank-at-work or bank-by-mail programs), but that has nothing to do with listing your open and closed branches.