WASHINGTON – CUNA and NAFCU have lent their support to thepossibility of changing a word on how ATM deployers disclose theirfees to machine users. Currently, if an ATM deployer charges a feefor the use of the machine it must notify the user in a prominentand conspicuous way that a fee will be imposed for the transaction.But with the advent of more ATM programs which are fee-free to thecardholder, the Federal Reserve is considering allowing ATMdeployers whose machines are part of such networks to replace the“will” with a “may.” Both associations, along with NASCUS,supported the possible change. “We believe that making adistinction between ATMs that charge fees for all transactions andthose which only charge for certain transactions will better assistconsumers in locating ATMs that may not charge a fee fortransactions they may need,” CUNA wrote in its October 7 letter. Inits comment letter, NASCUS states that the fee structure of afinancial institution and the decision to determine what productswill and will not incur fees should be determined by theinstitution. “It is legitimate that some customers may incur fees,while others may not,” states the NASCUS comment letter. “Consumersunderstand preferred pricing structures. Many industries practicepreferred pricing, including airlines and grocery stories, to namea few.” NAFCU wrote that “the current regulation mandating the useof the term will in all cases, whether or not an ATM operatorimposes a fee, is overly restrictive and likely to cause confusionin consumers. If signage posted on an ATM states that a fee will becharged even though certain transactions or consumers (due tonetwork agreements) are surcharge-free, the consumer may notattempt a transaction thinking that there will be a surcharge.”

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