The US ISO Committee hosted a conference call with the Sponsoring Financial Institutions (SFI) Committee for clarification and/or discussion on items to ease the burden and streamline efforts on the ISO and to come up with processes agreeable to all. From this call the ISO Committee respectfully requested that discussion continue among the SFI Committee on the following items: 

• Agreement on one standard application and addendum based on new regulations (ISO Committee provided a suggested Network Compliance Form) requesting the minimal amount of information
  
• Provide a compilation of all applicable network rules that ISO’s can provide to their merchants
  
• SFI’s work directly with the processors, so there is no need for duplicate applications, and an ATM can only then be connected with the approval from the SFI
  
• Provide a compilation of baseline standards of reasons for rejecting a customer
  
• Provide more information to the ISO’s as to why the information is requested
  
• Provide a clearinghouse for application information
  
• Provide a hot-line for notification on non-compliant ATMs 
  

The ISO Committee will schedule a conference call shortly to review the outcome of these discussions and to discuss the next steps.
 
If you are interested in more information or participating on this committee, please feel free to contact lana@atmia.com.
 
The US Government Relations Committee (GRC) is continuing their work in New York pushing bills initiated by the GRC, that are good for both the citizens of New York and for those businesses whose livelihood depends upon the merchant owned and operated ATM, including a bill providing that buildings housing ATMs are included within the covered buildings for purposes of the crime of burglary in the second degree.  This bill is on its way to the codes committee with written documentation from police agencies.
 
It was reported that there is not expectation of any movement on any ATM bills in New York in this session. It has come to the GRC’s attention that the Utah, Florida, and New York international surcharge bills wording do not qualify to “override” the regulation preventing surcharges on non-US cardholders, according to Visa and MasterCard. The bills wording is considered permissive versus required. It was reported that the Utah Attorney General is preparing an action against Visa in this regard.  The Florida bill sponsor was contacted requesting a chapter amendment prior to the Governor signature, by sending it back to the final house of passage. As Florida is no longer in session this was not an option. If need be, the GRC will file an amendment when Florida is in session, March of 2007. 

If any member plans on initiating this type of bill in their state, please contact lana@atmia.com, so you can make sure you have the correct wording.
 
It was reported that the California Department of Financial Institutions will be writing a letter in opposition to the California AB 2969 requiring the Department of Financial Institutions to prepare a report by July 1, 2007, that makes recommendations on how to limit the sale and purchase of automated teller machines to the general public. 

The US Sponsoring Financial Institutions (SFI) Committee has subcommittees working on:

• Anti-Money Laundering by reviewing the FFIEC Bank Secrecy Act Anti-Money Laundering Examination Manual and addressing any gaps they may have in their ATM and AML policies.
  
• PIN Security by updating the PIN Review Mapping to including the TG-3-2006 that was recently made available for public use, with the addition to address public key cryptography.
  
• Education by scheduling a conference call to review the need for updating the ISO training workshop information and to discuss the date for subsequent training.
  
• ISO requests for easing the burden and streamlining efforts on the ISO and to come up with processes agreeable to all.
  

Further thoughts…ISOs have about 17 weeks to obtain owner (and/or cash loading) information from their merchants. Unless an SFI has a variance, they will be out of compliance and will be subject to penalties unless they notify the ISO and Processor to shut them down. The networks are very clear that sponsor FIs of non compliant ATMs can be assessed up to $15,000 each and no SFI will take a chance of incurring such substantial penalties.  MasterCard has already given a 4 month variance, and there is no indication from Visa that a global variance will be given. Many ISOs have not started this project, while many more have completed it.  Hopefully the networks will take into consideration those ISOs that expended the time, money and resources to stay in compliance when considering if they will grant additional time.

The Canada ISO Committee hosted a conference call with MasterCard to obtain clarification regarding the new MasterCard regulations as they relate to Canada ATM Owners. From this discussion, it was decided that the US and Canadian ATMIA ISO Committees will write a letter to MasterCard referencing that they represent X number of MasterCard network transactions per year, requesting a counter proposal that would satisfy all parties.  This letter will also include the requirements that have already been implemented by Interac.