Answer:
No. FinCEN concluded in 2007 that a nonbank owner/operator of an ATM that offers customers of a depository institution no service other than remote access to such customers’ accounts at those depository institutions for the purposes of making balance inquiries or currency withdrawals, would not be a money services business for purposes of the BSA and its implementing regulations. Therefore, an independent ATM owner or operator may not be separately regulated as a financial institution at the state or federal level.
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