Receipts at Electronic Terminals

Receipts at electronic terminals

1. The amount of the transfer.

This amount may include the amount of a transfer fee—if the amount of the fee appears on the receipt and on or at the electronic terminal. [12 CFR 1005.9(a)(1)] Putting the fee on a paper receipt, however, will not satisfy the Section 16 paper notice option (described below under the heading “ATM fee disclosure”) if the receipt comes at the end of the transaction because Section 16 requires that the paper notice come before the consumer is committed to paying the fee. [Commentary, 12 CFR 1005.9(a)(1)-2.ii.]

The institution can meet the “on or at the electronic terminal” requirement “by displaying the fee on a sign at the terminal or on the terminal screen for a reasonable duration.” [Commentary, 12 CFR 1005.9(a)(1)-1, emphasis added] As we point out later, Section 16 of Regulation E requires both a posted notice and paper or ATM screen notice. [Commentary, 12 CFR 1005.9(a)(1)-2.i.] If the institution uses the terminal screen for the Section 9 fee notice, the consumer must have the option of canceling the transaction after the notice appears. [Commentary, 12 CFR 1005.9(a)(1)-1] Finally, keep in mind that the Section 9 requirements apply to “electronic terminals,” while the Section 16 rules apply only to ATMs. [Commentary, 12 CFR 1005.9(a)(1)-2.iii.]

2. The date of the transfer.

This is the calendar date the consumer uses the terminal—not the business or accounting date of the transfer. You can show these other dates on the receipt if you wish but, if you do, you must distinguish them clearly. [Commentary, 12 CFR 1005.9(a)(2)-1]

3. The type of transfer and the type of account to or from which the transfer was made.

Types of transfers include withdrawals, transfers from one account to another, and payments. Types of accounts can be described generally as “checking” (for checking, share draft or NOW accounts) or “savings” (for savings or share accounts). [Commentary, 12 CFR 1005.9(a)(3)-1] If the consumer’s access device can only access one type of account at the terminal, your receipt does not have to show the account type. [12 CFR 1005.9(a)(3)] If the access device can access more than one account of the same type at a terminal, you must identify the particular account that the consumer accessed in the transaction. [Commentary, 12 CFR 1005.9(a)(3)-3] For example, the receipt might say, “Withdrawal from Checking I.”

4. A number or code that identifies the consumer, the account, or the access device.

It is your choice whether the number or code is to identify the consumer’s account or the access device. [12 CFR 1005.9(a)(4)] The objective is to include some identifier that will link the consumer to the transfer.

Prior to April 1995, the requirement was that the number or code “uniquely” identifies the consumer, the account, or the access device. The FRB amended the regulation at that time because of concerns that a unique identification would further ATM fraud. (See the Federal Register for March 22, 1995, at page 15032.) The word “uniquely” was removed from the requirement. Furthermore, the regulation now says that the number or code need not exceed four digits or letters.

5. The location or identification of the electronic terminal.

The receipt must include either the location of the electronic terminal or some other means of identifying the terminal, such as a code or terminal number. [12 CFR 1005.9(a)(5)] If you include an identification code or terminal number, you are permitted to include it in a transaction code. [Commentary, 12 CFR 1005.9(a)(5)-1.ii.]

If you opt for the location, you must include the city and state or foreign country and one of the following: (1) the street address, (2) a generally accepted name for the specific location, or (3) the name of the owner or operator of the terminal if other than the account-holding institution. [12 CFR 1005.9(a)(5)] The city need not be included if the generally accepted name [number (2) above] includes the city name. [Commentary, 12 CFR 1005.9(a)(5)-2] You need not include either the city or the state if all the terminals owned or operated by the financial institution providing the statement (or by the system in which it participates) are located in the same city. [Commentary, 12 CFR 1005.9(a)(5)-4] Furthermore, the state need not be included if all the terminals owned or operated by the financial institution that provides the statement (or by the system in which it participates) are located in that state, or all transfers occur at terminals located within 50 miles of the financial institution’s main office. [Commentary, 12 CFR 1005.9(a)(5)-3]

6. The name of any third party to or from whom the funds were transferred.

You can use codes for this—if you explain the codes elsewhere on the receipt. If the identity of the third party is supplied by the consumer in a manner that makes it impossible for the terminal to identify the third party on the receipt, then this requirement does not apply. For instance, if the consumer inserts a payment stub into the ATM to identify the payee, the receipt need not identify the payee. But, if the consumer keys in the identity of the third party, the requirement does apply. [Commentary, 12 CFR 1005.9(a)(6)-1]

Those are the required elements of the terminal receipt. We have just a few more general comments about the receipt before we go on to the next topic. First, you can set up the terminal to provide the receipt only upon the request of the consumer if you want. [Commentary, 12 CFR 1005.9(a)-1] The Regulation only requires that you make the receipt available at the time of the transaction, not that you actually provide it in each case. Second, the receipt must be in written form that the consumer can retain. [12 CFR 1005.4(a)] Written form includes electronic form. See the heading “Special rules for electronic disclosures” above for more information. Third, although the Regulation has no type size or other specific format requirements, it does require that the information on the receipt be set forth clearly. [Commentary, 12 CFR 1005.4(a)-1] Therefore, you should be careful that any codes you use are identified, that numbers do not run together, that the information is somewhat organized, and so forth. And finally, you can arrange with a third party, such as a merchant or the operator of an ATM system, to provide the receipt on your behalf. [Commentary, 12 CFR 1005.9(a)-2]