I am not well versed in CRA and our CRA officer is on leave so I was hoping to get feedback from BOLers.

We are planning to remove several stand alone depository ATMs in rural and urban areas. We include them in our assessment areas. Under CRA are we required to provide customer/ regulator notice prior to removing them?

CRA itself does not impose any obligation to post closings in advance or to get regulatory approval. It does however require you to maintain in your public file a list of branch openings and closings during the past two calendar years plus the current year.

The answer may also depend on whether you are state chartered, the state may require notice of the removal of an ATM. So will the AA change, or are these rural and urban areas you mentioned in your AA because of significant activity and being services by full service financial centers?

One of your required policies addresses branch closing. Federal regulators don't recognize an ATM as a branch. As PR noted, you could have state requirements addressing this. If an ATM is a "branch" it should be in your policy, and the exclusion may also be noted in that policy.

Strategically you may have other considerations. Include your CRA officer in the discussion. Do these ATMs allow you to reach/serve an otherwise unbanked or LMI area? Have you touted these ATMs for that or any other reason? Shutting them down could have a negative impact if that were the case. Document why it was closed, low traffic, high cost, high crime, etc... Also, if your CRA Public File has a list of ATMs it will need to be updated if you close this one.