My bank is an Intermediate Small Bank, and we are considering placing some ATMs in grocery stores located way outside our assessment area. They would not be deposit-taking (so no worries about adjusting our assessment area delination), just cash dispensing machines. The areas they would go to are middle income, distressed/underserved rural areas in the middle of nowhere.

Here's my question: Do you think we would earn CRA credit for placing machines in these areas? I'm just not sure we would. After all, users of the machines would still have to have a deposit account (probably not with us, since the nearest branch would be a good 150 miles away), so I think examiners might not think we are providing any real service.

Thoughts? Thank you!

A couple exams ago I had an FDIC examiner tell me placing ATMs in distressed areas outside our AA would be viewed by him as possibly taking advantage of LMI consumers, since the non-customers would be charged. This is purely anectdotal, so please take it with a grain of salt.

IMO it will be hard to justify service credit for these ATMs other then you offer ATM machines for your customers to use. Which are part of your retail services

You will need to prove the ATM's revitalizes or stabilizes the community and help meet the "Essential" community needs including the needs of low and modertae income individuals.

If the ATMs are just convience items, and you cannot show how many low and modertae income individuals use them IMO you have no chance at getting CRA credit.

Thanks everyone. That is the same line of thought I was having.