FDIC issues narrower interpretation of ITM deployment

On August 9, the FDIC released a narrower “ Classification of Interactive Teller Machines as Domestic Branches or Remote Service Units”.  In order to avoid being considered a bank branch, ITMs must now meet the following requirements:

• The ITM is an automated, unstaffed banking facility owned or operated by, or operated exclusively for, the bank, which is equipped to enable existing customers1 to initiate an interactive session with remotely located bank personnel; and,
• To the extent that bank personnel have the ability to remotely assist the customer with the operation of the ITM to perform core banking functions, customers must also be able to perform such transactions without the involvement of bank personnel and must have the sole discretion to initiate and terminate interactive sessions with bank personnel.

State nonmember banks may also provide access to ITM facilities to non-customers as long as the ITM services available to non-customers are limited to the same functionality typically provided by an Automated Teller Machine (ATM) to non-customers (e.g., withdrawal of cash) and such users are unable to engage a live remote teller to remotely perform core banking functions for the customer.

ATMIA’s Financial Institution ATM Deployers Forum group will discuss this development at their quarterly meeting August 21, 2024. The meeting is open only to bank and credit union members of ATMIA.

The FDIC announcement and related documents are available with the link below.

https://www.fdic.gov/news/financial-institution-letters/2024/classification-interactive-teller-machines-domestic