What Notice Must an ATM Operator Give You About a Fee? A Regulation E Guide

If you have ever pulled cash from an out-of-network ATM, you've probably seen a small screen pop up warning you about a fee before you confirm the transaction. That screen is not just a courtesy. Federal banking examiners check that ATM operators give you this fee notice, either on the screen or on paper, before you're committed to paying it. Here's what the rule actually requires, and what a compliant notice looks like in practice.

The rule behind that warning screen

The requirement comes from Regulation E, the federal rule that governs electronic fund transfers. Regulation E is issued by the Consumer Financial Protection Bureau under the authority of the Electronic Fund Transfer Act. Within that regulation, Section 1005.16 specifically addresses ATM fee disclosures, and FDIC examiners are instructed to confirm that a financial institution operating a fee-charging ATM shows both the fee and its dollar amount on-screen or on paper before the consumer is committed to paying it. That timing detail matters: the notice has to appear before you commit to the transaction, not as a receipt line item after the cash is already dispensed. The current version of this rule was published on December 27, 2011, and it was later amended on March 26, 2013.

On-screen versus paper: what's different

ATM operators generally have two ways to satisfy this notice requirement: display it on the ATM's screen, or print it on paper. The choice matters for one specific reason. If an operator chooses the paper route instead of the screen, that paper notice has to be something you can actually keep, a retainable format. That retainability rule only kicks in for the paper option, it does not apply when the fee is simply shown on the ATM screen. Either way, the wording of the notice itself must meet Regulation E's general 'clear and readily understandable' disclosure standard, discussed next.

What the notice has to say, not just when

Timing and format are only part of the picture. The actual wording of the fee notice also has to meet Regulation E's general content standard, which requires disclosures to be clear and readily understandable. That standard, found elsewhere in Regulation E at 12 CFR 1005.4(a), is applied specifically to the content of ATM fee notices.

Anatomy of a compliant fee notice

Picture a typical out-of-network ATM screen that reads: "This ATM will charge you a fee of $3.00 for this transaction. Do you want to continue?" That mirrors what examiners are instructed to verify: that the fee and its dollar amount both appear on-screen or on paper before the consumer is committed to paying it. Here's how that maps to the requirements.

A sample fee notice illustrating the screen-or-paper, before-the-fee standard examiners check for

Notice element	What it must include	Why it matters
Fee disclosure	A statement that a fee applies, plus the dollar amount	Examiners confirm both the existence and the amount of the fee are shown before the consumer is committed to paying it
Timing	Shown before the consumer is committed to paying the fee	The notice must appear before the consumer is committed to paying the fee, not merely before the withdrawal finishes
Format	On-screen, or paper if retainable	Paper notices must be retainable; screen notices carry no such requirement
Wording	Clear and readily understandable	The notice's content must meet Regulation E's general clarity standard

Worked example: a fee notice in action

Say you walk up to an out-of-network ATM and request cash. Before the machine dispenses anything, a screen appears disclosing that a fee applies to the transaction and the exact dollar amount of that fee, and asks whether you want to continue. Because that disclosure shows both the fee and its amount before you confirm the transaction, it satisfies the before-the-fee timing standard examiners check for. If the screen's wording were vague, such as listing only a fee range instead of a specific dollar amount, that would raise a question under the clear and readily understandable content standard that applies to this notice. And if this particular ATM instead printed the notice on a paper slip rather than showing it on-screen, that slip would need to be one you could keep.

• withdrawal: 60
• fee: 3
• Formula: withdrawal + fee
• Result: 63

Key takeaways

• An ATM operator must show you the fee and its exact dollar amount on-screen or on paper before you're committed to paying it.
• If the operator uses a paper notice instead of an on-screen one, that paper must be retainable; on-screen notices carry no such retainability requirement.
• The wording of the notice itself must be clear and readily understandable under Regulation E's general disclosure standard.
• This requirement sits in Regulation E, issued by the CFPB under the Electronic Fund Transfer Act.
• The rule's current text was published on December 27, 2011, and later amended on March 26, 2013.

Does the fee notice have to show the exact dollar amount, or can it just say a fee applies?

Examiner guidance specifically checks that the notice includes both the fee and its amount, not just a general warning that a fee exists.

Can an ATM operator give me the fee notice after I've already withdrawn the cash?

No. The notice has to appear before you are committed to paying the fee, which examiners confirm by checking that the disclosure happens prior to that commitment point.

Do on-screen fee notices need to be something I can print or save?

No. The retainable-format requirement applies only to printed paper notices, not to notices displayed on the ATM screen.

What federal rule actually governs this notice?

It's part of Regulation E, which the Consumer Financial Protection Bureau issues under the Electronic Fund Transfer Act.

If an ATM ever dispenses cash without showing you a fee amount beforehand, or if a posted notice feels vague about what you'll actually be charged, that's worth noting. Examiners are instructed to confirm that the fee and its amount are shown on-screen or on paper before you're committed to paying it, mirroring the text of the rule itself.

Sources

• www.fdic.gov
• www.ecfr.gov
• www.law.cornell.edu