Not sure if this is the correct forum for this question. Are other banks treating Interactive Teller Machines (ITM) as "electronic terminals" under the definitions of Reg E? The client puts in their card and PIN and then decides whether or not to initiate through the existing ATM channel or use the Teller Assist channel. In the case of Teller Assist, a teller verifies the client and then initiates the transaction for the client like they would if they were in the branch. They can cash a check, deposit a check with cash back or perform a w/d for the client and instruct the machine to dispense cash. The teller is who is performing the transaction and the client entering their card and PIN at the beginning of the transactions is doing so the teller can identify them.


An electronic fund transfer is any transfer of funds that is initiated through an electronic terminal, telephone, computer, or magnetic tape for the purpose of ordering, instructing, or authorizing a financial institution to debit or credit a consumer’s account.

An electronic terminal is an electronic device, other than a telephone operated by a consumer, through which a consumer may initiate an electronic fund transfer.

Thoughts??

I also would like to know the answer to this as well. ITMs are beginning to surface and there have been some questions about this equipment and process/procedures.

Anyone ever respond to this question?

please see
https://www.consumerfinance.gov/rules-policy/regulations/1005/2/#2-h-Interp-3
3. Teller-operated terminals. A terminal or other computer equipment operated by an employee of a financial institution is not an electronic terminal for purposes of the regulation. However, transfers initiated at such terminals by means of a consumer's access device (using the consumer's PIN, for example) are EFTs and are subject to other requirements of the regulation. If an access device is used only for identification purposes or for determining the account balance, the transfers are not EFTs for purposes of the regulation.