I know I've seen a question about this recently, so I'm sorry to be asking again, but I can't seem to find the previous post. I'm doing a Privacy review and I came to the OCC exam question (which I'm using as guidance) pertaining to 12CFR 40.9(b)(1)(iv) which states about delivering a Privacy and Opt Out Notice: "For an isolated transaction with the consumer, such as an ATM transaction, posts the notice on the ATM screen and requires the consumer to acknowledge receipt of the notice as a necessary step to obtaining the particular financial product or service." Does anyone do this? I've never seen this on any ATM that I've used.

The ATM user is not your consumer if all you are doing is acting to provide a banking service on behalf of another institution.