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January 25, 2012


Robert Schwalb, Esq., NCCO


ATM's located in commercial facilities may be exempt from compliance. For example, if XYZ Corp. Employees FCU has an ATM located within the XYZ plant that is accessible only to XYZ employees said ATM may be exempt. I strongly recommend each credit union that has an ATM in such locations get legal opinions regarding this issue.

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