ATM Compliant Signage

SIGHTLINE PAYMENTS|CASINO ATM ALERT| SURGE IN REGULATION E LAWSUITS

ATM Compliant Signage

Sightline Payments LLC cautions casino operators to be alert to ATMs located on their casino floors to ensure signage on all their ATM terminals follows Regulation E and Network requirements. There is a recent surge of Regulation E lawsuits being filed against ATM terminals deployed across the country that are out of compliance. To help provide some protection to your casino business against these lawsuits, Sightline Payments recommends you check each ATM to ensure that they prominently display the required signage. The required signage includes Fee Notice, Operational Problems or Suspicious Activity and network brands. The Fee Notice directly relates to Regulation E. For more information on these requirements please call Sightline Payments at 702-851-4747.
Upon recent visit by Sightline Payments staff to five prominent Las Vegas strip casino properties we found three of the five out of compliance. The American Bankers Association states “An ounce of prevention is worth several pounds of cure”. A quick look now could help insulate you later from a class-action litigation “gotcha” that has the potential to turn the Federal Reserve’s Regulation E into Regulation “Expensive.”
The “on machine” ATM notice requires a notice in a “prominent and conspicuous location” on the ATM that a fee may be imposed. It is this second set of disclosures that is generating litigation. The provisions of Regulation E governing ATM disclosures have been interpreted by the Federal Reserve as requiring both “on machine” and “screen/paper” notices. Confusingly, there was a period of time when the FDIC’s Compliance Examination Handbook suggested that providing one or the other form of disclosure, but not both, complied with the statute.
Are these lawsuits legitimate concern?
Most give the appearance of being filed mostly for their nuisance or settlement value. The EFTA caps class action damages at the lesser of $500,000 or 1% of the net worth of a defendant (plus attorney fees and costs). The statute also provides a defendant with excellent grounds to respond to the suit should they choose to defend rather than settle. The following web-site is yet another example of how claims are being solicited against your business www.classactionconnect.com
As a precautionary measure casino operators should take a date and time stamped photo of the ATM terminal displaying compliant signage as evidence of compliance at that point in time should the casino become involved in a class action lawsuit involving non-compliance to Regulation E.
It is advisable to ensure signage is compliantly displayed each time a terminal is visited. Have your in house slot technicians carry signage to replace missing signage and a disposable time/date stamped camera to take the signage photo. It is suggested the time and date stamped photos be archived so a chronology can be provided as necessary.
These simple steps should assist in the protection and defense of these lawsuits.
Alerting the gaming industry on important issues like this is one more example of how Sightline Payments is on your side.
The Sightline Payments LLC Team- Kirk Sanford, Tom Sears, and Diran Kludjian


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Court extends gay military ban pending appeal

The 1993 "Don't ask, don't tell" measure has opponents and supporters
A federal appeals court has ordered the US military's ban on openly gay troops to remain in place indefinitely while a legal battle is fought over the policy.

The court had last month issued a temporary injunction blocking a judge's ruling that overturned the 17-year-old "don't ask, don't tell" law.

The government argues that it should stay in place until the military has devised a new policy.

The ruling means troops can still be discharged for being openly gay.

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The Obama administration has voiced support for ending "Don't ask, don't tell" but argues that any repeal of the policy should be undertaken by Congress, not the courts.

The Pentagon is currently assessing the impact that allowing openly gay servicemen and women may have on military readiness and effectiveness, and is due to release a report on 1 December.

Over the past few weeks, the defence department has been bounced between legal rulings first allowing, then denying, homosexual men and women the right to enlist.

Ten days ago, US Defence Secretary Robert Gates issued a new mandate that only five senior officials, all civilian, could expel someone from the military for being gay.

Prior to this change, a large number of less senior officials, both civilian and military, could decide to discharge gay servicemen and women.










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