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#2306381 - 02/21/25 07:05 PM FDIC 328
Compliance Action Subscriber 1226 Offline
100 Club
Joined: Sep 2015
Posts: 209
Our customers can do transfers between accounts at the ATM, no check or cash deposits. We attached the FDIC decal to the ATM - should we remove the decal?

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#2306392 - 02/21/25 08:26 PM Re: FDIC 328 Compliance Action Subscriber 1226
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,692
The decal is not required since your ATMs do not accept deposits. There isn't any guidance that I have seen that would specifically require you to remove the decal.

From the FDIC FAQs:
5. If an ATM allows transfers of funds between deposit accounts but does not accept cash or check deposits, is the ATM subject to the sign requirements described in section 328.4?

Answer: No. The sign requirements in section 328.4 only apply to IDIs’ ATMs and other remote electronic facilities that “receive deposits,” and accepting cash or checks are examples of deposits.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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