When you dispute an ATM withdrawal, your bank investigates by pulling the machine’s electronic transaction journal, physically auditing the cash left inside the ATM, and reviewing security camera footage from the terminal. Federal law — the Electronic Fund Transfer Act and Regulation E — sets the deadlines and requires the bank to tell you the outcome in writing.1eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors How much you can recover depends heavily on how quickly you reported the problem.
The Three Things a Bank Checks
The ATM’s Electronic Journal
Every ATM keeps a digital log, commonly called an Electronic Journal, that records each step of every interaction: the moment your card was read, the entry of your PIN, the exact amount requested, and whether the cash dispenser completed its cycle. After you file a dispute, the bank pulls this record for the date and time of your transaction.
Investigators look for error codes that signal a mechanical failure. A bill jam, a communication failure with the bank’s server, or a mismatch between the number of bills the machine counted internally and the number that reached the exit slot all leave a trace in the log. If the journal shows the dispenser completed the transaction cleanly, the bank moves to the next check.
The Physical Cash Audit
A bank employee or armored car service performs a manual count of the cash remaining in the machine’s currency cassettes and compares it to what the digital record says should be there. The math is straightforward. If the machine holds more cash than the ledger predicts, and the overage matches your disputed amount — an extra $200 sitting inside after you reported a missing $200 — that pairing is strong evidence the machine debited your account without dispensing the money.
If the cash count matches the ledger, or the machine is short, the records point the other way: the funds appear to have left the machine as requested. This phase turns on hard numbers and physical currency counts rather than anyone’s account of what happened at the terminal.
The Camera Footage
The bank then checks the digital and physical evidence against the video. ATMs typically have a camera near the screen or keypad that captures the person performing each transaction, and investigators often review wider-angle perimeter or nearby branch cameras as well.
A few things stand out during footage review. Was the cardholder actually at the machine, or did a third party use the card? Did the machine dispense cash and then retract it back inside after a timeout, as ATMs do when no one collects the money? Are there signs of tampering — a skimming device on the card reader, an overlay on the keypad?2Federal Bureau of Investigation. Skimming If the footage shows the person at the machine picking cash out of the dispenser, the bank will likely deny the dispute.
How Long the Investigation Takes
Federal law puts a clock on the bank. After receiving your notice of error, it has 10 business days to finish investigating and tell you the result. If it needs longer, it can extend the investigation to 45 days, but only if it deposits a provisional credit for the disputed amount into your account within those first 10 business days.1eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors That credit lets you use the money while the bank keeps reviewing logs, cash counts, and footage.
Three situations get longer timelines:
- If the disputed transaction happened within 30 days of the first deposit to a new account, the bank gets 20 business days to issue provisional credit and up to 90 days to complete the investigation.3Consumer Financial Protection Bureau. 1005.11 Procedures for Resolving Errors
- Point-of-sale debit card transactions carry a 90-day investigation window.1eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors
- Transfers not initiated within a U.S. state, such as a withdrawal from an ATM abroad, also get up to 90 days.1eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors
Under any of those extended timelines, the provisional credit deadline still holds, and the bank must report its findings within three business days of finishing the investigation.1eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors
How the Bank Tells You the Result
Once the bank finishes with the journal, the cash audit, and the video, it sends you a written notice of its findings.1eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors If the evidence supports your claim, any provisional credit already in your account becomes permanent and the case closes.
If the bank concludes no error occurred, or that a different error occurred, the notice must explain the findings and inform you of your right to request the documents the bank relied on.3Consumer Financial Protection Bureau. 1005.11 Procedures for Resolving Errors Any provisional credit will be reversed. Before pulling it back, the bank must tell you the date and amount of the reversal, and for five business days after that notice it must honor checks and preauthorized payments without charging overdraft fees.1eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors That buffer gives you time to adjust your balance before the money disappears.
Reporting Fast Protects You
How quickly you notify the bank sets a hard ceiling on what you can be forced to eat if the withdrawal turns out to be unauthorized. Federal law creates three tiers:
- Report within 2 business days of learning about the loss or theft, and your maximum liability is $50 or the amount of unauthorized transfers that occurred before you told the bank, whichever is less.4eCFR. 12 CFR 1005.6 – Liability of Consumer for Unauthorized Transfers
- Report after 2 business days but within 60 days of the statement, and your liability can rise to $500.4eCFR. 12 CFR 1005.6 – Liability of Consumer for Unauthorized Transfers
- Wait more than 60 days after the statement was sent, and you face unlimited liability for unauthorized transfers occurring after that window closes.5Consumer Financial Protection Bureau. 1005.6 Liability of Consumer for Unauthorized Transfers
The 60-day clock starts when the bank sends the periodic statement showing the unauthorized transaction, not when you open it. Errors covered by the investigation rules include unauthorized withdrawals, receiving the wrong amount of cash, a transaction posting for a different amount than requested, and transfers missing from your statement entirely.1eCFR. 12 CFR 1005.11 – Procedures for Resolving Errors
If the Bank Denies Your Dispute
A denial isn’t the end. Start by asking the bank for copies of every document it relied on. Federal law requires the bank to provide them promptly on request, and to convert any machine-readable data into a format you can actually read.3Consumer Financial Protection Bureau. 1005.11 Procedures for Resolving Errors Reviewing the transaction logs, cash audit results, and footage summaries yourself may surface inconsistencies worth raising in a follow-up appeal.
If the bank won’t resolve the issue, you can file a complaint with the Consumer Financial Protection Bureau. The CFPB accepts complaints about checking and savings accounts, including ATM disputes, and forwards them to the bank.6Consumer Financial Protection Bureau. Submit a Complaint Companies generally respond within 15 days, though some cases take up to 60. Complaints can be filed online or by phone at (855) 411-2372, Monday through Friday, 8 a.m. to 8 p.m. ET.
Where the bank has violated the investigation process itself — missing the provisional credit deadline, blowing past the investigation window, or failing to provide the written explanation — you may have grounds to sue under the Electronic Fund Transfer Act. A noncompliant bank is liable for your actual losses, statutory damages between $100 and $1,000, and reasonable attorney’s fees.7Office of the Law Revision Counsel. 15 USC 1693m – Civil Liability The bank can escape liability only by showing the violation was an unintentional, good-faith error made despite reasonable procedures designed to prevent it.