Answer:
If those states have no requirements the KISS rule would indicate that you may follow the strictest guidelines. That may be deemed an excessive expense, however. And as a result, you may want to just take "ordinary" safety precautions to protect your customers, employees and assets and spend a little less, but meet some internally defined guidelines. As an example you may have a policy on the lighting that isn't up to the highest code, but is sufficient for your situation. That is, you may have a big savings reducing the candlefoot power slightly. And you'd still have bushes no closer than 20 feet, not have ATMs in secluded areas or high crime locations, etc.
The elements you'd consider are those you already do but with an emphasis on defending this in court instead of to a regulator. Was it a safe environment? In some cases even meeting state laws may not protect you when your customer was injured at your ATM. It is risk management.
First published on BankersOnline.com 11/29/04
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