Answer:
I am not aware of any regulations that require daily ATM settlement or deposit processing. If you are doing image-exchange presentment of the checks in the ATM deposits, those checks shouldn't be treated as cash items when they are removed from the machine. If you are NOT doing image-exchange presentment, it appears that you are giving customers credit on items you might not process for up to seven days later -- a decidedly risky situation, I think.
Image-capable ATMs should provide you a means to compare check images and transaction amounts to identify keying errors and make adjustments. If you cannot do that without pulling the actual checks from the machine, you've got a problem. As for presenter errors, there are usually remotely-accessible logs that can identify and flag them and other sorts of machine faults.
I don't imagine that your bank would have purchased an ATM with this new technology without getting details on the enhancements from the vendor. ATM settlement is certainly a matter that the vendor should have addressed. I urge you to meet with those involved in the purchase and installation decision to express your concerns and to hear how they've got these bases covered.
First published on BankersOnline.com 6/09/08
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