AUTOMATED 

TELLER MACHINES

Some Consumer Fees 

Have Increased

Report to Congressional Requesters

April 2013

GAO-13-266

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-266, a report to 

congressional requesters

April 2013

AUTOMATED TELLER MACHINES 

Some Consumer Fees Have Increased

Why GAO Did This Study

Since the 1960s, consumers have 

increasingly used ATMs to easily

access their accounts and conduct 

transactions such as cash withdrawals. 

Consumers may incur fees to use 

ATMs, such as a “surcharge” fee, 

which is paid to the ATM operator for 

transactions conducted at ATMs 

outside their financial institution’s 

network. In 2008, GAO reported that 

ATM surcharge fees had increased

since 2000. GAO was asked to review 

issues related to continued increases 

in these fees. 

This report discusses (1) the business 

models for ATM operators and how 

they set ATM fees, (2) the amounts of 

fees that consumers incur to conduct 

ATM transactions and how these fees 

have changed over time, and (3) the 

reported costs of ATM operations for 

ATM operators and how the costs and 

revenues are expected to change.

For this work, GAO surveyed a 

nongeneralizable sample of 30 

financial institutions and 4 independent 

ATM operators to collect information 

on their ATM operations and costs in 

calendar year 2011. In addition, GAO 

analyzed two types of ATM fees data 

obtained from firms specializing in the 

financial services industry: (1) data on 

fees charged by financial institutions 

from 2007 to 2012 that are 

generalizable to all financial institutions 

in the United States, and (2) 

nongeneralizable data on fees charged 

by independent ATM operators that 

were procured by “mystery shoppers” 

at 100 judgmentally selected 

independent ATMs in 2012. GAO also 

interviewed industry representatives 

and federal regulators to understand 

ATM operations and requirements.

What GAO Found

Automated teller machine (ATM) operators include financial institutions—banks 

and credit unions—as well as independent firms. Industry representatives GAO

spoke with estimate there are approximately 420,000 ATMs in the United States. 

They estimate that financial institutions operate and set the fees for about half of 

the market, and independent operators work together with merchants to operate 

the remainder and to determine the fees incurred by consumers. ATM operators 

have differing business models that affect the way they set ATM fees for 

consumers. Financial institutions operate ATMs as a convenience to their own 

account holders, who generally do not pay fees to use these ATMs, while nonaccount-holding customers do. At independent ATMs, most consumers incur a

surcharge fee, although there are some exceptions, such as when the ATM is

part of a surcharge-free ATM network. 

GAO estimates that the prevalence and amount of ATM surcharge fees charged 

by financial institutions have increased since 2007, and that the estimated 

average surcharge fee for financial institutions that charged a fee increased from 

$1.75 in 2007 to $2.10 in 2012, in 2012 dollars. In 2012, surcharge fees charged 

by financial institutions ranged from $0.45 to $5.00. GAO’s analysis of a 

nongeneralizable sample of 100 ATMs run by independent operators found that 

the average surcharge fee was $2.24 and ranged from $1.50 to $3.00 in 2012.

However, some independent ATMs may have surcharge fees that are higher or 

lower than those in GAO’s sample. In contrast, GAO estimates that the foreign 

fee—the fee assessed by financial institutions for using an ATM outside the 

institution’s network—generally stayed constant in dollar amount over this period. 

Consumers have many ways to obtain cash without incurring fees, such as using 

ATMs within their financial institution’s network. Additionally, some financial 

institutions participate in surcharge-free networks that allow their customers free 

access to ATMs outside their institution’s ATM network. These networks can 

greatly expand the number and location of ATMs available to consumers free of 

charge. 

GAO’s analysis of the ATM cost data reported by a nongeneralizable sample of 

financial institutions it surveyed revealed some differences in the biggest cost 

drivers for ATM operations. For example, large banks’ reported costs for 

hardware and software investments were higher as a percentage of their 

reported total ATM costs than for the midsize banks and credit unions. Key cost 

drivers reported by the nongeneralizable sample of independent ATM operators

varied, but commonly reported costs were rent, infrastructure, and transaction 

processing. In addition, most of the surveyed ATM operators reported that overall 

per-ATM costs have increased over the past 5 years, while per-ATM revenues 

have declined. Many of the operators GAO contacted believe that ATM operation 

costs will continue to rise in the future and that revenues will be flat or decline.

View GAO-13-266. For more information, 

contact Alicia Puente Cackley at (202) 512-

8678 or CackleyA@gao.gov. 
Page i GAO-13-266 Automated Teller Machines

Letter 1 

Background 4

Business Models for Financial Institutions and Independent ATM 

Operators Impact How Fees Are Set 8

Some ATM Fees Have Increased, but Often Consumers Can Avoid 

Incurring Fees 13

ATM Operators Have Varying Costs, and Many Operators 

Anticipate Costs Will Rise 22

Agency Comments 32

Appendix I Objectives, Scope, and Methodology 33

Appendix II Selected Results from GAO’s Survey on ATM Operator 

Costs and Operations 40

Appendix III Analysis of the Estimated Prevalence and Average Amount 

of ATM fees from 2007 to 2012 48

Appendix IV GAO Contact and Staff Acknowledgments 57

Tables

Table 1: Fees Paid by Consumers, Financial Institutions, and ATM 

Owners to Process ATM Transactions 8

Table 2: Description of Primary Independent ATM Operator 

Business Models 11

Table 3: Number of Financial Institutions Surveyed by Moebs 

$ervices, 2007-2012 37

Table 4: Financial Institution ATM Operators in GAO Survey 40

Table 5: Independent ATM Operators in GAO Survey 41

Table 6: Number and Types of ATM Transactions Reported by All 

Financial Institutions in GAO Survey, Calendar Year 2011 42

Table 7: Number and Types of ATM Transactions Reported by 

Large Banks in GAO Survey, Calendar Year 2011 42

Contents 
Page ii GAO-13-266 Automated Teller Machines

Table 8: Number and Types of ATM Transactions Reported by 

Midsize Banks in GAO Survey, Calendar Year 2011 43

Table 9: Number and Types of ATM Transactions Reported by 

Credit Unions in GAO Survey, Calendar Year 2011 43

Table 10: Number and Types of ATM Transactions Reported by 

Independent ATM Operators in GAO Survey, Calendar 

Year 2011 43

Table 11: Per-ATM Costs for Financial Institution ATM Operators 

in GAO Survey, Calendar Year 2011 45

Table 12: Estimated Percentage of Financial Institutions Charging a 

Surcharge Fee, by Type of Financial Institution and Year 

(2007-2012) 49

Table 13: Estimated Percentage of Financial Institutions Charging a 

Foreign Fee, by Type of Financial Institution and Year 

(2007-2012) 49

Table 14: Estimated Average Surcharge Fee, by Type of Financial 

Institution and Year (2007-2012) 50

Table 15: Estimated Average Foreign Fee, by Type of Financial 

Institution and Year (2007-2012) 50

Table 16: Estimated Percentage of Financial Institutions Charging a 

Surcharge Fee, by Size of Financial Institution and Year 

(2007-2012) 51

Table 17: Estimated Percentage of Financial Institutions Charging a 

Foreign Fee, by Size of Financial Institution and Year 

(2007-2012) 51

Table 18: Estimated Average Surcharge Fee, by Size of Financial 

Institution and Year (2007-2012) 52

Table 19: Estimated Average Foreign Fee, by Size of Financial 

Institution and Year (2007-2012) 52

Table 20: Estimated Percentage of Financial Institutions Charging a 

Surcharge Fee, by Location of Financial Institution and 

Year (2007-2012) 53

Table 21: Estimated Percentage of Financial Institutions Charging a 

Foreign Fee, by Location of Financial Institution and Year 

(2007-2012) 53

Table 22: Estimated Average Surcharge Fee, by Location of 

Financial Institution and Year (2007-2012) 54

Table 23: Estimated Average Foreign Fee, by Location of Financial 

Institution and Year (2007-2012) 54

Table 24: Estimated Percentage of Financial Institutions Charging a 

Surcharge Fee, by Region of Financial Institution and Year 

(2007-2012) 55
Page iii GAO-13-266 Automated Teller Machines

Table 25: Estimated Percentage of Financial Institutions Charging a 

Foreign Fee, by Region of Financial Institution and Year 

(2007-2012) 55

Table 26: Estimated Average Surcharge Fee, by Region of Financial 

Institution and Year (2007-2012) 56

Table 27: Estimated Average Foreign Fee, by Region of Financial 

Institution and Year (2007-2012) 56

Figures

Figure 1: ATM Transaction Flow for “Off-Us” Cash Withdrawals 6

Figure 2: Estimated ATM Fees Charged by Banks and Credit 

Unions, 2007-2012 15

Figure 3: Estimated Average Surcharge Fee, by Size, Type, 

Location, and Region of Financial Institution, 2012 17

Figure 4: Estimated Average Foreign Fee, by Size, Type, Location, 

and Region of Financial Institution, 2012 18

Figure 5: Top Five Costs Borne by Financial Institution ATM 

Operators in GAO Survey, as a Percentage of Reported 

Total Costs 26
Page iv GAO-13-266 Automated Teller Machines

Abbreviations

ABA American Bankers Association

ADA Americans with Disabilities Act

ATM automated teller machine

ATMIA ATM Industry Association

CFPB Bureau of Consumer Financial Protection

EFT electronic funds transfer 

FDIC Federal Deposit Insurance Corporation

ICBA Independent Community Bankers of America

NCUA National Credit Union Administration

OCC Office of the Comptroller of the Currency

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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Page 1 GAO-13-266 Automated Teller Machines

United States Government Accountability Office

Washington, DC 20548

April 11, 2013

The Honorable Charles E. Schumer

The Honorable Tom Harkin

The Honorable Bernard Sanders

The Honorable Tom Udall

The Honorable Sheldon Whitehouse

United States Senate

Since the 1960s, consumers have increasingly used automated teller 

machines (ATM) to conveniently and quickly access their bank accounts 

and conduct transactions, including withdrawing cash, making balance 

inquiries, and depositing cash or checks. Consumers sometimes pay fees 

for conducting ATM transactions, which can include both a fee paid to the 

ATM operator (“surcharge” fee) and a fee paid to their own financial 

institution (“foreign” fee) when they use an ATM outside that institution’s 

ATM network. According to industry estimates, the ATM business has 

grown substantially since the mid-1990s—from an estimated 165,000 

ATMs in 1997 to 420,000 in 2012. In 2009, the most recent year for which 

data on ATM transactions are available, U.S. consumers made an 

estimated 6 billion withdrawals from ATMs, totaling $646.7 billion.1 We 

have reported in the past that ATM surcharge fees increased between 

2000 and 2006.2

You asked us to review issues related to surcharge fees and what might 

be driving any increases. This report discusses: (1) the business models 

for ATM operators—financial institutions and independent firms—and how 

they set ATM fees; (2) the amounts of fees that consumers incur to 

conduct ATM transactions and how these fees have changed over time; 

and (3) the reported costs of ATM operations for financial institutions and 

independent ATM operators and how the costs and revenues are

expected to change.

 

1

Federal Reserve System, The 2010 Federal Reserve Payments Study: Noncash 

Payment Trends in the United States: 2006 – 2009 (Washington, D.C.: April 2011).

2

See GAO, Bank Fees: Federal Banking Regulators Could Better Ensure that Consumers 

Have Required Disclosure Documents Prior to Opening Checking or Savings Accounts, 

GAO-08-281 (Washington, D.C.: Jan. 31, 2008).

 
 

Page 2 GAO-13-266 Automated Teller Machines

To address these objectives, we reviewed prior GAO, regulatory, and 

industry reports on ATM fees and operations, and we interviewed relevant 

officials from the Board of Governors of the Federal Reserve System (the 

Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), the 

Office of the Comptroller of the Currency (OCC), the National Credit 

Union Administration (NCUA), and the Bureau of Consumer Financial 

Protection, commonly known as CFPB. We also interviewed 

representatives from several banks, a credit union, and three independent 

ATM firms; industry associations; three electronic funds transfer (EFT) 

networks; a financial institution that sponsors independent ATM 

operators; and a consumer protection group.

For the first objective and third objective, we interviewed and surveyed 

financial institution and independent ATM operators to collect information 

on their business operations and models, transaction levels for calendar 

year 2011, and what factors they take into account when setting fees. The 

survey also collected information on costs—for calendar year 2011—

across 12 categories that we developed in consultation with industry 

representatives and staff from the Federal Reserve and CFPB. The 

survey was deployed to the 10 largest banks and credit unions (by asset 

size) and 10 randomly selected midsize banks (with assets between $10 

billion and $50 billion). We received responses from 9 out of 10 large 

banks, 8 out of 10 midsize banks, and 9 out of 10 credit unions. We 

designed and deployed a separate survey to four independent ATM 

operators that operate 10,000 or more ATMs and received responses 

from two.3 We were not able to independently verify the cost information 

submitted by survey respondents. However, we asked the respondents to 

tell us what sources they used in calculating the costs they reported. They 

relied on sources such as internal accounting reports and third-party bills. 

Based on the source information provided and follow-up calls with survey 

respondents, we determined the data they reported were sufficiently 

reliable for our purposes. In addition to the survey, we interviewed one 

large and two smaller independent ATM firms and held two group 

interviews with representatives from nine community banks, in order to 

 

3

We originally intended to deploy the survey to 10 independent ATM operator firms. 

However, our pretests revealed that the survey would have been overly burdensome for 

smaller firms, so we limited our outreach to the 4 firms that, according to our research, 

had more than 10,000 ATMs.
 

Page 3 GAO-13-266 Automated Teller Machines

obtain general information on their ATM costs and operations.4 None of 

the costs or operations data we collected are generalizable to ATM 

operators at-large. Due to the sensitive and possibly proprietary nature of 

the information we collected with the survey, we aggregate the cost data 

at a high level and present it in a way that prevents individual 

organizations from being identified.

For the second objective, we analyzed data we purchased from two 

market research firms that specialize in the financial services industry. 

We obtained data on fees charged by banks and credit unions from 2007 

through 2012 from Moebs $ervices, Inc. (Moebs). Moebs collected the 

data through telephone surveys with financial institutions selected using a 

stratified random probability sample, and therefore, when weighted, the 

data are generalizable to all financial institutions in the United States. We 

computed weighted estimates and 95 percent confidence intervals of the 

percentage of institutions charging surcharge and foreign fees and 

weighted averages and medians of these fees. We also examined the 

differences between the estimated prevalence, or percentage of 

institutions that charged each fee, and average fees for type and size of 

financial institution, as well as geographic region and type of location of 

the financial institution separately. We did not conduct a multivariate 

analysis using all of these factors, control for all factors at once, or control 

for additional factors in our analysis. We adjusted the dollar amounts of 

fees for inflation to remove the effect of changes in prices. The inflationadjusted estimates used a base year of 2012 and Consumer Price Index 

calendar year values as the deflator. We relied on past interviews, 

analysis of the Moebs data, and the methodology report provided by 

Moebs, as well as reasonableness checks we conducted on the data we 

received to identify any missing, erroneous, or outlying data. We 

concluded that the data were sufficiently reliable for our purposes. Data 

on ATM fees charged by independent operators are not available, so we 

engaged the services of another research firm—Informa Research 

Services—to conduct “mystery shops” at 100 judgmentally selected 

independent ATMs in the top 10 metropolitan statistical areas.5 The 

 

4

Community banks can be defined based on a number of criteria, but for the purpose of 

this report, we use size (less than $10 billion in assets) as the sole criterion to distinguish 

community banks from their larger counterparts. 

5

A metropolitan statistical area is a geographic entity defined by the Office of Management 

and Budget for use by federal statistical agencies in collecting, tabulating, and publishing 

federal statistics. A metropolitan area contains a core urban area population of 50,000 or 

more.
 

Page 4 GAO-13-266 Automated Teller Machines

mystery shop process involved having a shopper go to each selected 

ATM and use his or her own debit card to conduct a transaction and 

document several aspects of the transaction, including the fee that he or 

she incurred. Our sample of independent ATM operators focused on 

ATMs in grocery stores, drug stores, gas stations, and liquor stores. 

These data indicate what independent ATM fees were on a particular day 

in 2012 at those 100 ATMs and are not generalizable to the population of 

independent ATMs in the United States.

We conducted this performance audit from November 2011 to April 2013, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. See appendix I for a more 

detailed description of our scope and methodology.

ATM transactions involve several different participants, including the 

customer at the terminal (the “consumer”); financial institutions such as 

banks, thrifts, and credit unions; and other entities involved in 

electronically processing transactions. Financial institutions typically issue 

debit cards to account holders that can be used for purchases at the point 

of sale or to conduct ATM transactions. ATM owners can be depository 

institutions, such as banks and credit unions, or public or private 

companies, such as merchants or independent operators that specialize 

in offering ATMs and related processing and support services.6

Independent operators may own their ATMs as well as provide ATMs 

under contract to merchants (for which the independent operators provide 

processing and other support services). Some independently owned 

ATMs are “branded” ATMs, where an independent firm owns and 

operates the machine but a financial institution pays for the right to 

display its logo on the terminal and to allow its customers to access the 

machine free of charge. Independent ATM operators must have a 

depository institution that sponsors their membership in the EFT networks 

 

6

There are several types of independent ATM operators that are not affiliated with a 

financial institution. These can include independent sales organizations, independent ATM 

deployers, and independent ATM operators or processors. In this report we use the term 

“independent ATM operator” to refer to all types.

Background 
 

Page 5 GAO-13-266 Automated Teller Machines

that process ATM transactions. Financial institutions have a relationship 

with account holders outside of ATM transactions, while independent 

ATM operators’ sole relationship with the consumer is through use of the 

ATM.

The EFT networks provide the infrastructure that allows funds to be 

transferred electronically and provide a means for an ATM card from one 

financial institution to be used at another financial institution’s or 

independent operator’s ATM. EFT networks route transactions between 

the ATMs and the card-issuing financial institutions and act as a 

clearinghouse to settle those transactions. They establish the rules and 

requirements for any financial institution that chooses to participate in the 

EFT network. These networks perform millions of transactions monthly.

The steps involved in an ATM transaction depend on whether or not a 

consumer uses an ATM owned by his or her financial institution (typically 

referred to as an “on-us” transaction) or an ATM owned by another 

financial institution or firm (typically referred to as an “off-us” transaction). 

On-us transactions are not routed through the EFT networks but instead 

are processed internally by the consumer’s financial institution.7 In both 

cases, the ATM transaction begins when the consumer inserts the ATM 

or debit card into an ATM, enters the personal identification number, 

selects the transaction to be performed—such as a cash withdrawal from 

the consumer’s checking account—and enters the amount of the 

transaction.8 For off-us transactions, the terminal sends this information to 

the sponsoring financial institution to identify the card-issuing financial 

institution, which determines the EFT network used to route the 

 

7

Industry representatives told us some smaller financial institutions use a third-party firm 

to process “on-us” ATM transactions.

8

In addition to cash withdrawals, consumers can conduct other transactions at an ATM 

such as checking account balances or making deposits; however, cash withdrawals are 

the most common transactions conducted at ATMs, as shown by our survey results in 

appendix II. Credit cards can also be used at ATMs to withdraw cash. However, ATM 

operators are not always able to track whether or not a transaction was initiated with a 

debit card or a credit card. For example, in our survey, out of the 26 financial institutions 

that responded to the question, only 11 said they could track the frequency of credit cardbased transactions at their ATMs, and reported between 0.3 and 5 percent of the 

transactions at their ATMs used a credit card in calendar year 2011. The other fifteen 

operators responded “unable to determine.” 
 

Page 6 GAO-13-266 Automated Teller Machines

transaction.9 The EFT network passes the request for authorization to the 

consumer’s financial institution, which approves or denies the transaction 

based on the terms and conditions of the consumer’s account and the 

availability of funds. The approval or denial message is sent back to the 

ATM terminal, first through the EFT network and then through the 

sponsoring bank. If the transaction is authorized, the consumer receives 

the requested cash, and the transaction is posted to the consumer’s 

account, deducting the amount of money the consumer received at the 

ATM plus any fees assessed. Using the EFT network, the consumer’s 

financial institution pays the ATM owner the withdrawal amount plus any 

assessed surcharges. Figure 1 depicts the transaction flow among the 

parties involved in an off-us ATM transaction.

Figure 1: ATM Transaction Flow for “Off-Us” Cash Withdrawals

Several fees can be paid by the consumer and the other participants in 

order to process an ATM transaction.10 Consumers may be charged two 

types of fees. First, the ATM owner may assess a surcharge fee on the 

consumer for conducting a transaction at the ATM. Federal regulations 

 

9

The ATM sponsoring financial institution is the entity that sponsors access to the EFT 

network. Therefore banks and credit unions are their own sponsoring financial institutions. 

Sometimes the sponsoring financial institution is referred to as the “acquirer.” 

10This report focuses exclusively on the fees paid to conduct transactions at ATMs in the 

United States. 
 

Page 7 GAO-13-266 Automated Teller Machines

require ATM operators to provide notice that the surcharge fee will be 

imposed and disclose the amount of the fee on the ATM screen before 

the consumer commits to paying the fee.11 Surcharge fees also appear on 

the transaction receipt and again on the consumer’s account statement—

sometimes combined with the cash withdrawal amount. Second, a foreign 

ATM fee is a fee that may be assessed by the consumer’s financial 

institution when the consumer uses an ATM owned by another ATM 

operator. The foreign ATM fee is not disclosed at the ATM. Rather it is 

provided to consumers in information they receive when they open their 

account, in fee disclosures, and on their periodic statements when they 

incur the fee.12

 

11Regulation E implements the Electronic Fund Transfer Act, the primary federal statute 

that governs the disclosure of ATM fees. 15 U.S.C. §§ 1601, 1693-1693r. Regulation E 

requires ATM operators that charge a fee to provide notice that a fee will be imposed and 

disclose the amount of the fee. 12 C.F.R. §1005.16. On December 20, 2012, the 

President signed into law a bill that eliminated the statutory requirement that the fee be 

posted on the outside of the ATM, so now only the on-screen notice is required. 15 U.S.C. 

§1693b(d)(3)(B), (2013) amended by Pub. L. No. 112-216, 126 Stat. 1590 (2012). 

12Regulation E requires financial institutions to provide consumers with initial disclosures 

of the terms and conditions of EFT services. 12 C.F.R. §1005.7. In addition, Regulation 

DD, which implements the Truth in Savings Act, requires depository institutions to 

disclose, among other things, the amount of any fee that may be imposed in connection 

with an account and the conditions under which such fees are imposed. 12 C.F.R. § 

1030.4. Banks, thrifts, and credit unions are subject to supervisory oversight, which 

includes on-site examinations and other steps, to enforce compliance with the relevant 

laws and regulations that pertain to ATM transactions. The Bank Service Company Act, 12 

U.S.C. §§ 1861-1867(c), permits examination and regulation of bank service companies or 

independent servicers performing under a contract or otherwise any service for a federally 

regulated depository institution by the appropriate federal banking agency of the 

depository institution acquiring the service, which includes OCC, the Federal Reserve, and 

FDIC. See 12 U.S.C. § 1867(c). The Federal Reserve has supervisory responsibility for 

state-chartered banks that are members of the Federal Reserve System, as well as bank 

holding companies and their nonbank subsidiaries, other than savings institutions and 

credit unions. 12 U.S.C. § 1844(c)(2)(A)(i)-(ii). FDIC oversees state-chartered banks and 

savings associations with federally insured deposits that are not members of the Federal 

Reserve System. 12 U.S.C. §§ 1813(q)(2), 1819(a). OCC oversees national banks and 

federal savings associations. 12 U.S.C. §§ 481, 1813(q)(1). NCUA oversees federally 

chartered and state-chartered credit unions whose member accounts are federally 

insured. 12 U.S.C. § 1784. State-chartered banks, thrifts, and credit unions are also 

subject to supervision by the state in which they are chartered. CFPB examines insured 

depository institutions and credit unions with more than $10 billion in assets as well as 

entities with which they have third-party contracts, such as independent ATM operators 

and network providers, to assess compliance with federal consumer financial laws. Pub. L. 

No. 111-203, §§ 1002(26),1025(d).
 

Page 8 GAO-13-266 Automated Teller Machines

The consumer’s financial institution and the ATM operator also pay 

certain fees to process an ATM transaction. Specifically, the interchange 

fee is set by the EFT networks and paid by the consumer’s financial 

institution to the ATM owner for the costs of placing and maintaining 

ATMs. The switch fee is assessed by the EFT networks on the 

consumer’s financial institution to pay for processing each of its network 

transactions. Finally, the acquiring fee is paid by the ATM owner to the 

EFT networks for use of the networks to conduct the ATM transaction. 

Table 1 provides a summary of the fees paid by consumers, financial 

institutions, and ATM operators during an ATM transaction.

Table 1: Fees Paid by Consumers, Financial Institutions, and ATM Owners to Process ATM Transactions

Fee Who pays Who receives Description

Surcharge fee Consumer ATM owner Paid to the ATM owner by the consumer when using 

an ATM not owned by his or her financial institution. 

Foreign fee Consumer Consumer’s financial 

institution

Paid to the consumer’s financial institution by the 

consumer when using an ATM not owned by the cardissuing financial institution.

Interchange fee Consumer’s financial 

institution

ATM owner Paid to the ATM owner for the costs of operating and 

maintaining the ATM.

Switch fee Consumer’s financial 

institution

EFT networks Paid to the EFT networks for routing transaction 

information over the network. 

Acquiring fee ATM owner EFT networks Paid to the EFT networks for the use of the network by 

the ATM owner. 

Source: GAO analysis of Federal Reserve and industry documents.

Financial institutions and independent ATM operators have different 

business models and, as a result, set ATM surcharge fees differently. 

Financial institutions operate ATMs as a convenience to their own 

account holders, who generally do not pay fees to use these ATMs. 

However, financial institutions do assess a surcharge fee when a 

transaction is conducted by nonaccount-holding consumers. Independent 

ATM operators charge surcharge fees to most customers, and in many 

cases operators work with merchants to determine those fees.

Business Models for 

Financial Institutions 

and Independent ATM 

Operators Impact 

How Fees Are Set
 

Page 9 GAO-13-266 Automated Teller Machines

According to industry estimates, there are approximately 420,000 ATMs 

currently operating in the United States, and financial institutions operate 

just under half of those machines, either in their own facilities or at off-site 

locations, such as shopping centers, drug stores, and grocery stores. 

Those financial institutions that responded to our survey—representing 

81,833 ATMs—reported they placed 57 percent of their total ATM fleet at 

bank facilities, while 43 percent were located off site.13 Financial 

institutions typically own or operate their ATMs. In some cases, financial 

institutions partner with independent firms to operate branded ATMs that 

carry the financial institution’s logo and look and function as if they belong 

to the institution but are owned by an independent ATM operator. As 

previously discussed, under these arrangements, the account holders for 

that financial institution are allowed to use the branded ATMs without 

paying a fee.

Financial institution representatives told us they view access to ATMs as 

a key service they provide to account holders. A representative from a 

large national bank said that its personal banking business is driven by 

customer convenience. Therefore they view access to ATMs as an 

important service to their account holders and have invested in a large 

fleet of ATMs for customer use. Likewise, a community banker we 

interviewed said that they view their ATMs as a way of extending the 

bank’s hours for customers to receive cash and make deposits. 

Representatives from two large national banks said that they consider 

where their customer base is located when determining where to place an 

ATM. One large bank representative noted that the bulk of the bank’s 

ATM business is its own customers, so it invests in ATMs and places 

them in locations near the greatest numbers of account holders. Financial 

institutions that have smaller fleets of ATMs, such as some credit unions 

and community banks, may offer their account holders access to ATMs 

by participating in a surcharge-free network. When a financial institution 

enrolls in a surcharge-free network, all ATMs in that network are available 

to their account holders surcharge free.

 

13As previously discussed, we surveyed a total of 30 financial institutions—the 10 largest 

banks and 10 largest credit unions (by asset size) and 10 randomly selected midsize 

banks (with assets between $10 billion and $50 billion). Response rates for this question 

were: 9 large banks, 9 credit unions, and 8 midsize banks. For these and all other survey 

data, the period covered is calendar year 2011. For more survey results, see appendix II.

Financial Institutions 

Operate ATMs Primarily 

for Their Own Account 

Holders, Often with No 

Fees
 

Page 10 GAO-13-266 Automated Teller Machines

Financial institutions generally do not charge their own account holders 

for transactions conducted within their own ATM network. When 

establishing surcharge fees charged to nonaccount-holding customers, 

the financial institutions we surveyed most frequently cited three factors 

that they consider, the first being competition—the fees being charged by 

nearby ATMs.14 Likewise, one bank representative we interviewed said 

that they do not want the fee to be so high that they turn away potential 

customers; instead, they want account holders from other financial 

institutions to use their ATMs and based on that experience, open 

accounts at their bank. Similarly, one of the community bankers we spoke 

to said that they try to set their fee just below those of other ATMs in the 

area so that they can increase their own transaction volume. In contrast, 

a few industry representatives told us that generally fees are set higher at 

areas where there is more limited ATM competition, such as airports and 

amusement parks.

The second most cited factor by survey respondents that they consider 

when setting surcharge fees was cost of operating the ATM.15 However, 

several of the financial institution officials we interviewed noted that the 

surcharge fees do not cover the costs of operating their ATMs, and the 

institution takes a loss on the ATM to provide the service to its account 

holders. The third most frequently cited factor the surveyed financial 

institutions take into account when setting surcharge fees was anticipated 

usage, or transaction levels.16 For example, representatives from two 

large banks noted that surcharge fees help ensure ATM availability for 

their account holders while also making the service available as a 

convenience for nonaccount-holding customers. Furthermore, the 

surcharge revenues at some locations can subsidize expensive or 

unprofitable ATM locations such as airports, colleges, and business 

districts.

 

14Our survey included a question asking what factors are taken into account when setting 

fees. Eight large banks, eight midsize banks, and nine credit unions responded to this 

question. We analyzed those responses and grouped them into like categories. 

Competition was the most frequently cited factor the financial institutions take into account 

when setting fees, mentioned by 16 survey respondents. 

15Cost was cited by 13 respondents as a factor they take into account when setting 

surcharge fees. 

16ATM usage levels were cited by six respondents as a factor they take into account when 

setting surcharge fees. 
 

Page 11 GAO-13-266 Automated Teller Machines

Independent ATM firms—those not part of a financial institution—own, 

operate, or service just over half of the nation’s ATMs in a variety of 

locations, such as gas stations and convenience stores, bars, 

restaurants, and small businesses, according to industry sources.17 The 

independent ATM industry is very diverse, with firms ranging in size from 

fewer than five ATMs to tens of thousands. According to information we 

have gathered, the two largest independent firms operate an estimated 

47 percent of the independent ATM market. In addition to owning and 

operating their own ATMs, these independent firms offer a wide range of 

ATM-related services to merchants and other entities that own ATMs, 

such as monitoring and maintaining appropriate cash levels in terminals 

and processing transactions. There are four primary business models for 

independent ATM operators, shown in table 2.

Table 2: Description of Primary Independent ATM Operator Business Models

Name of

business model Independent operator responsibilities Merchant responsibilities

Turnkey Owns the ATM and is responsible for most aspects of its 

operations, including ATM monitoring, managing and loading 

cash, replacing supplies, and providing maintenance, 

customer-service support, and transaction processing. 

Provides a place to locate the ATM and an 

electric outlet to power it.

Merchant-Assisted Owns the ATM, provides all transaction processing, performs 

ATM monitoring and related customer-service support, and, in 

some cases, performs maintenance for more complicated 

problems.

Provides and loads cash as well as performs 

basic maintenance.

Merchant-Owned & 

Loaded

Provides transaction-processing services, ATM monitoring, 

and other services, such as customer-service support and 

arranging for advanced maintenance. 

Owns the ATM, responsible for the majority 

of the operations, including basic 

maintenance and managing and loading 

cash.

Merchant CashAssistedProvides and loads cash, and provides transaction-processing 

services, ATM monitoring, and other services, such as 

customer service support and arranging for advanced 

maintenance. 

Owns the ATM, responsible for operations, 

including basic maintenance, but not 

managing and loading cash.

Source: GAO analysis of industry reports.

According to the ATM Industry Association, approximately 20 percent of 

the independent ATMs in the United States are owned by an independent 

ATM firm. The other 80 percent of independent ATMs are owned by 

 

17We obtained this information from the ATM Industry Association. In addition, two major 

EFT networks—based on their industry knowledge—also told us they estimated that 

independent ATM operators run half or just over half of the ATMs in the United States.

Independent ATM 

Operators Work with 

Merchants to Operate 

Terminals and Set Fees
 

Page 12 GAO-13-266 Automated Teller Machines

merchants and retailers. In these situations, independent ATM firms 

provide varying levels of nonownership services and support to 

merchants, depending on the business model established. We found that 

the independent ATM firms included in our study had similarly diversified 

portfolios, where they both owned and operated ATMs while also 

providing services to merchants who owned the ATMs in their stores. We 

also found that, among the firms in our study, there was great variability 

as to the percentage of ATMs owned by the firm versus the merchant. For 

example, one smaller independent firm we spoke with owned 79 percent 

of the approximately 500 ATMs in its fleet, while the remaining 21 percent 

were merchant owned. In contrast, the two independent firms that 

participated in our survey—representing approximately 66,000 ATMs—

owned 2 percent of their ATMs, while merchants owned the other 98 

percent.

Independent ATM operators generally levy a surcharge on consumers, 

although there are exceptions. Unlike financial institutions, which have a 

relationship with consumers who are also account holders through which 

they can gain revenue from other account fees, independent ATM 

operators’ only relationship with the consumer is through their use of the 

ATM. Most independent ATM operators charge a surcharge fee to 

consumers for the convenience of accessing their account from a 

machine outside their bank’s ATM network. In addition, as previously 

discussed, those consumers may be charged a foreign fee by their own 

bank for using these independent ATMs (or ATMs run by financial 

institutions other than their own). However, some transactions at 

independent ATMs are surcharge free because the ATMs may be bankbranded or may be part of one or more surcharge-free networks.

When placing, operating, and servicing ATMs in retail space, independent 

ATM firms establish contracts with the merchants that specify which party 

will set the surcharge fee and how, if at all, those and other fee revenues 

will be shared. For turnkey and merchant-assisted ATMs, the surcharge 

fees are generally set by the independent ATM firms because they own 

the machines.18 For ATMs that are owned by merchants or retailers in the 

United States, the fees are set by either the merchant or a combination of 

the merchant and the independent ATM firm. A representative from one 

 

18According to one independent ATM firm, in some cases the contract for an ATM 

placement may stipulate that both the merchant and independent ATM operator mutually 

consent to the amount of the surcharge fee. 
 

Page 13 GAO-13-266 Automated Teller Machines

independent firm said that if the ATM is owned by the merchant, the firm 

is not involved in setting the surcharge fee, except to make suggestions 

to the merchant or to refuse to process the transaction if it determines the 

fee is exorbitant.

Like financial institutions, when setting surcharge fees, independent 

operators typically consider fees at the nearby ATMs, the location, and 

operating costs. A representative from one independent ATM firm said 

that the market dictates the surcharge fee and he can only charge what 

his competitors are charging. The location of the ATM is also considered 

when setting the surcharge fee. Another independent operator said he 

considers the type of location where the ATM will be placed and the 

resulting demographic that will frequent that area. He evaluates what fee 

is competitive for the region or neighborhood and the type of location. For 

example, some ATMs have lower fees because they are placed in lower 

income areas. Another firm representative said that the surcharge fee in 

bars, nightclubs, and casinos is typically higher than the surcharge fee in 

a grocery store. The third factor is the cost of running the ATM terminal. 

An independent ATM operator we spoke with said that the firm 

establishes fees that, when combined with other revenues such as 

interchange fees, will provide sufficient revenue to cover the variable cost 

of processing transactions and the fixed cost of installing the ATM.

Our review found that since 2007, surcharge fees assessed by financial 

institutions have generally increased. We also found that the percentage 

of financial institutions charging foreign fees and the amount ATM users 

pay in foreign fees has remained constant. However, consumers can 

obtain cash without paying ATM fees in a number of ways, such as using 

their own banks’ ATMs or requesting cash back at the point of sale.

Some ATM Fees Have 

Increased, but Often 

Consumers Can Avoid 

Incurring Fees
 

Page 14 GAO-13-266 Automated Teller Machines

Our analysis shows that the prevalence and amount of ATM surcharge 

fees levied by financial institutions have generally increased since 2007, 

while foreign fees have generally remained constant in prevalence and 

amount, as seen in figure 2.19 We analyzed data obtained from a private 

vendor—based on annual surveys of hundreds of banks, thrifts, and 

credit unions on selected banking fees—and found that the percentage of 

financial institutions charging surcharge fees rose from an estimated 87 

percent to 96 percent from 2007 through 2012.20 Of those institutions that 

charged a surcharge fee, the estimated average ATM surcharge fee 

increased from $1.75 in 2007 to $2.10 in 2012.21 The estimated median 

ATM surcharge fee rose from $1.56 in 2007 to $2.00 in 2012. Surcharge 

fees charged by financial institutions in our sample ranged from $0.28 to 

$5.52 in 2007, and the range was $0.45 to $5.00 in 2012. Meanwhile, 

foreign fees did not significantly change in prevalence and amount from 

2007 to 2012. Our analysis of the data shows that the estimated 

percentage of financial institutions charging their customers a foreign fee 

between 2007 and 2012 has remained fairly constant at about 55 percent. 

In addition, our analysis shows that for institutions that charge a foreign 

 

19As previously discussed, we analyzed data from a private vendor, Moebs $ervices, Inc. 

(Moebs), to assess ATM fees charged by financial institution ATM operators. Moebs 

provided data gathered through telephone surveys for each of the years 2007 through 

2012, based on statistically representative samples of financial institutions. We computed 

weighted estimates and 95 percent confidence intervals of the percentage of institutions 

charging surcharge and foreign fees and weighted averages and medians of these fees. 

All percentage estimates presented in this report have a margin of error of +/- 5 

percentage points or fewer, and all average and median estimates have a relative margin 

of error of +/-5 percent or less, unless otherwise noted. All differences between estimated 

values in this report are statistically significant at the 95 percent confidence level (p-value 

<= 0.05), unless otherwise noted. For more detailed information on the characteristics of 

the data, see appendix I.

20Our analysis focused on surcharge and foreign fees for cash withdrawals. However, a 

small percentage of other transactions that occur at the ATM incur fees. See appendix II 

for survey results on these other fees. 

21Unless noted otherwise, dollar amounts for ATM surcharge and foreign fees in this 

report are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values. We analyzed the prevalence of charging a surcharge and foreign fee, and then we 

excluded financial institutions that did not charge a fee from our calculation of the average 

fees. In our previous work on ATM fees, we calculated the average ATM surcharge and 

foreign fee by averaging the fee charged by all institutions, including those that did not 

charge a fee, and reported those numbers in 2006 dollars. See GAO, Bank Fees: Federal 

Banking Regulators Could Better Ensure that Consumers Have Required Disclosure 

Documents Prior to Opening Checking or Savings Accounts, GAO-08-281 (Washington, 

D.C.: Jan. 31, 2008).

ATM Surcharge Fees 

Assessed by Financial 

Institutions Have 

Increased, While Foreign 

Fees Remained Constant 
 

Page 15 GAO-13-266 Automated Teller Machines

fee, the estimated average fee did not significantly change between 2007 

($1.36) and 2012 ($1.42). The estimated median foreign fee was $1.09 in 

2007 and $1.00 in 2012.22 Foreign fees charged by financial institutions in 

the sample ranged from $0.28 to $5.52 in 2007, and the range was $0.25 

to $5.00 in 2012.

Figure 2: Estimated ATM Fees Charged by Banks and Credit Unions, 2007-2012

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values. We computed weighted estimates and 95 percent confidence intervals of the percentage of 

institutions charging surcharge and foreign fees and weighted averages and medians of these fees. 

All percentage estimates presented in this report have a margin of error of +/- 5 percentage points or 

fewer and all average and median estimates have a relative margin of error of +/-5 percent or less, 

unless otherwise noted.

 

22The median estimates for 2007 and 2012 are not significantly different; the median 

estimate for 2012 has a margin of error of ±$0.15 and a relative margin of error of ±15 

percent.
 

Page 16 GAO-13-266 Automated Teller Machines

We estimate that there were no statistically significant differences in 2012 

in the prevalence of the surcharge fee based on the type and size of 

institution, or on geographic region or location—such as rural, urban, or 

suburban—in which the financial institution was located.

23 The estimated 

average surcharge fee amount, for institutions that charged a fee, differed 

slightly by size and type of financial institution.24 In 2012, the estimated 

average surcharge fee for larger financial institutions was approximately 

$0.24 higher than the estimated average surcharge fee for smaller 

financial institutions, and banks’ estimated average surcharge fees were 

also $0.17 higher than the estimated average surcharge fees charged by 

credit unions.25 For example, in 2012, the estimated average surcharge 

fee for using a large financial institution’s ATM was $2.25, while the 

estimated average surcharge fee at a small financial institution’s ATM 

was $2.01. In contrast, there were no statistically significant differences in 

estimated average ATM fees in 2012 based on the type of location and 

geographic region in which the financial institution was located.26 See 

figure 3 for information on the estimated average surcharge fee amount 

based on several factors for 2012.

 

23We examined the differences between the estimated prevalence and average fees for 

type and size of financial institution, as well as geographic region and type of location of 

the financial institution separately. We did not conduct a multivariate analysis using all of 

these factors or control for any additional factors in our analysis. 

24We analyzed the estimated average, median, and range of ATM fees for all financial 

institutions from 2007 through 2012, but due to a large sample size, we chose to present 

the estimated averages in discussing differences in the amount of the surcharge fees for 

various types and sizes of institutions, or in geographic regions or types of areas, such as 

rural, urban, or suburban, in which the financial institution was located. 

25The Moebs data set defined small financial institutions as those with less than $10 

million in assets, medium financial institutions as those with $10 million to $999 million in 

assets, and large financial institutions as those with $1 billion or more in assets, so we 

used those definitions in our analysis of fees. 

26We also analyzed the variation in amount and prevalence of surcharge fees from 2007 

through 2011 based on the institution size and type, and type of location and geographic 

region in which the financial institution is located. Within each year, we examined the 

differences between the estimated average fees for these factors separately. We did not 

conduct a multivariate analysis using all of these factors or control for any additional 

factors in our analysis. See appendix III for more analysis of surcharge fees based on 

these factors for 2007 through 2012.
 

Page 17 GAO-13-266 Automated Teller Machines

Figure 3: Estimated Average Surcharge Fee, by Size, Type, Location, and Region of Financial Institution, 2012

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values. We analyzed the estimated average, median, and range of ATM fees for all financial 

institutions from 2007 through 2012, but due to the large sample size, we chose to conduct our 

analysis of variation in fees using the estimated averages. We examined the differences between the 

estimated average fees for type, size, location, and geographic region separately. We did not conduct 

a multivariate analysis using all of these factors or control for any additional factors in our analysis. 

Our estimates have relative margins of error at the 95 percent confidence level of +/- 5 percent or 

less, with these exceptions: financial institutions in large cities (+/- 7.9 percent).

We estimate that a higher percentage of large financial institutions 

charged a foreign fee in 2012 than small financial institutions. Specifically, 

an estimated 73 percent of large financial institutions charged a foreign 

fee in 2012 compared to an estimated 50 percent of small financial 

institutions. For those institutions charging the foreign fee, the estimated 

average fee amount was greater for large institutions and for banks. In 

2012, large financial institutions had an estimated average foreign fee of 

$1.62, which is $0.26 more than the estimated average foreign fee 

charged by small financial institutions, which had an estimated average 

foreign fee of $1.36. Additionally, the average foreign fee was an 
 

Page 18 GAO-13-266 Automated Teller Machines

estimated $0.23 higher at banks than credit unions in 2012.27 See figure 4 

for more information on the estimated average amount of foreign ATM 

fees based on various factors for 2012.

Figure 4: Estimated Average Foreign Fee, by Size, Type, Location, and Region of Financial Institution, 2012

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values. We analyzed the estimated average, median, and range of ATM fees for all financial 

institutions from 2007 through 2012, but due to the large sample size, we chose to conduct our 

analysis of variation in fees using the mean. We examined the differences between the estimated 

average fees for these factors separately. We did not conduct a multivariate analysis using all of 

these factors or control for any additional factors in our analysis. Our estimates have relative margins 

of error at the 95 percent confidence level of +/- 5 percent or less, with these exceptions: financial 

institutions in large cities (+/- 11.8 percent), suburban financial institutions (+/- 6.7 percent), financial 

institutions in the East (+/- 5.6), financial institutions in the South (+/- 5.7), and financial institutions in 

the West (+/- 6.7).

 

27We also analyzed the differences in the estimated average amount and prevalence of 

foreign fees from 2007 through 2011 based on the institution size and type, and type of 

location and geographic region in which the financial institution is located. Within each 

year, we examined the differences between the estimated average fees for these factors 

separately. We did not conduct a multivariate analysis using all of these factors or control 

for any additional factors in our analysis. See appendix III for more analysis of foreign fees 

based on these factors for 2007 through 2012.
 

Page 19 GAO-13-266 Automated Teller Machines

Historical or trend data for independent ATM operators’ fees are not 

available. However, we analyzed data from Informa Research Services 

on the fees charged by a judgmentally selected sample of 100 ATMs run 

by independent ATM operators in 2012.28 These data are not 

generalizable to the independent ATM population at-large.29 Our analysis 

of the Informa data shows that the average surcharge fee for the 100 

independent ATMs surveyed was $2.24 in 2012.30 The median surcharge 

fee for independent ATMs included in the sample was $2.00. The 

surcharge fee ranged from $1.50 to $3.00. However, some independent 

ATMs may have surcharge fees that are higher or lower than those in our 

sample. While we do not have historical data on independent ATM 

surcharges, representatives from a large independent ATM firm told us 

that their average surcharge fees rose from $1.77 in 2002 to $2.46 in 

2011.31

Aggregate data are also not available on the prevalence of surcharge 

fees among independent ATM operators. However, data obtained by 

mystery shoppers from a sample of 100 judgmentally selected 

independent ATMs in the top 10 metropolitan statistical areas, show that 

most of these ATMs charged a surcharge fee to the mystery shopper, but 

some transactions were conducted surcharge free. Specifically, in our 

sample of 100 independent ATMs, six mystery shoppers conducted a 

transaction for free using the selected ATM. In four of the six cases, the 

shoppers were able to conduct a transaction surcharge free since both 

 

28As previously discussed, we analyzed data from a private vendor, Informa Research 

Services, Inc. (Informa), to assess ATM fees charged by independent ATM operators in 

2012. The Informa data are from a nonrepresentative sample of independent ATM 

operators and were gathered by sending shoppers to selected ATMs to conduct a 

transaction and report their results. For more detailed information on the characteristics of 

data sets and the data reported by each vendor, see appendix I.

29Due to the judgmental and nongeneralizable sample of data we obtained from Informa, 

we are also unable to analyze differences in surcharge fees for independent ATMs based 

on the type or size of ATM operator or geographic region or type of area in which the 

independent ATM is located.

30As previously stated, our sample of independent ATM operators focused on ATMs in 

grocery stores, drug stores, gas stations, and liquor stores, and our sample is not 

generalizable to all independent ATMs in the United States.

31As previously discussed, dollar amounts for ATM surcharge fees in this report are in 

2012 dollars, calculated using the Consumer Price Index calendar year values. The 

nominal values for the average ATM surcharge fees reported by this independent operator 

were $1.39 in 2002 and $2.42 in 2011. 
 

Page 20 GAO-13-266 Automated Teller Machines

the ATM and the shopper’s debit card displayed the logo of a surchargefree network. In the other two cases where no surcharge was incurred, 

we sent a second mystery shopper to use the terminal, and the second 

shopper was charged a fee. We were unable to determine why the first 

mystery shoppers were not charged surcharge fees, but we did note that 

the ATMs had surcharge-free network logos on them.

The independent ATM firms we surveyed reported similar results to the 

mystery shopping data. The two independent firms reported in our survey 

that out of 140,634,638 cash withdrawals at their ATMs in calendar year 

2011, customers incurred a surcharge fee 97 percent of the time.32

However, the percentage of transactions that are surcharge free may vary 

depending on the extent to which the ATM operator is involved in 

surcharge-free networks or branding agreements. For example, one large 

independent ATM operator estimates that more than half of the 

transactions that occur on its ATMs do not generate a surcharge fee due 

to either a surcharge-free network or branding agreements.33

To obtain cash without incurring fees, consumers can generally withdraw 

cash at a bank branch during banking hours or use ATMs in their bank’s 

network. Our analysis indicates that a majority of transactions at financial 

institution ATMs may occur in this way. Specifically, according to our 

survey data, approximately 92 percent of the 3.3 billion reported 

transactions in calendar year 2011 at the financial institutions that 

responded did not incur a surcharge fee.34 At midsize and large banks we 

surveyed, ATM cash withdrawals did not incur a surcharge fee about 85 

percent of the time. Additionally, our survey results showed that cash 

withdrawals at credit unions were surcharge free 95 percent of the time. 

Further, some industry representatives told us that financial institutions’ 

ATMs typically have a higher volume of transactions than independent 

 

32The firms also reported on transactions other than cash withdrawals—balance inquiries, 

fund transfers, and denials—none of which incurred a surcharge. For more information, 

see appendix II.

33Although we interviewed officials from this firm and they submitted cost and revenue 

information to us, they did not complete the survey. While we were not able to 

independently verify these estimates, we do know there are independent ATM firms that 

have substantial branding and surcharge-free network programs.

34As previously discussed, all survey results are for calendar year 2011. 

Consumers Have Many 

Ways to Obtain Cash 

without Incurring Fees
 

Page 21 GAO-13-266 Automated Teller Machines

ATMs. While our survey results are not generalizable to the total 

population of ATM operators, they did reveal that per-ATM transaction 

levels were much higher at financial institution ATMs than at independent 

ATMs for operators responding to the survey. As previously discussed, 

bank representatives we spoke to said that transactions at their ATMs are 

primarily from their own account holders, who do not incur fees for the 

transaction, and a large EFT network estimated that 80 percent of ATM 

transactions are on-us transactions and do not incur a fee. Consumers 

also avoid paying foreign fees in on-us transactions, because they are 

using machines within their financial institution’s ATM network.35

However, all consumers may not have convenient access to their own 

financial institution’s ATMs to obtain cash. Some account holders may 

live in areas with limited access to a financial institution facility, or need 

cash at a time when they are unable to go to their own financial 

institution—for example when attending a sporting event or while 

travelling.

Additionally, some financial institutions participate in surcharge-free 

networks that allow their customers free access to ATMs outside their 

bank’s network of ATMs. In this way, a financial institution can expand the 

number and location of ATMs available to its customers. Three of the 

largest surcharge-free networks in the United States each offered more 

than 20,000 ATMs, and some customers whose financial institutions have 

enrolled in those networks can use those ATMs without incurring a 

surcharge fee.36 Four banks and eight credit unions in our survey reported 

that they participated in at least one surcharge-free network, expanding 

the number of surcharge-free ATMs available to their customers. For 

example, one credit union in the survey owned and operated 251 ATMs 

and enrolled in a surcharge-free network that gave its customers access 

to an additional 30,000 ATMs free of charge. However, ATMs in 

surcharge-free networks may not be available to all customers. One of 

the largest surcharge-free networks in the country states that 80 percent 

of the ATMs in its network are in metropolitan areas.

 

35As previously discussed, this report focuses exclusively on fees paid to conduct 

transactions at ATMs in the United States.

36As of February 2013, these three firms reported having 38,000, 30,000, and 23,000 

ATMs in their surcharge-free networks. However, since an ATM could be part of more 

than one surcharge free network, it is not possible to determine the number of distinct 

ATMs that participate in these three surcharge-free networks.
 

Page 22 GAO-13-266 Automated Teller Machines

Also, many financial institutions use branding agreements to expand their 

network of ATMs, which allows their consumers to withdraw funds from 

these ATMs without incurring fees. For example, the number of branded

ATMs with financial institution logos increased from 11,900 in 2010 to 

15,400 in 2011 for one large independent ATM operator, according to the 

operator’s annual reports. Among our surveyed financial institutions, 

branded ATMs accounted for approximately 16 percent of the total 

number of reported ATMs.37 One small independent ATM operator 

estimated that 55 percent of customers who use its ATMs pay a fee, and 

that percentage has decreased over the past 5 years due to an increase 

in financial institution branding and access to surcharge-free networks.

Some financial institutions offer to refund ATM fees to account holders 

when they use an ATM. One community banker we spoke to said the 

bank gives consumers rebates on ATM fees up to $20 each month and 

that this approach is more cost effective than owning and maintaining a 

fleet of ATMs. Finally, industry participants we spoke with said that 

consumers are increasingly obtaining cash when making debit card 

purchases, which also allows them to avoid fees. One community banker 

we spoke to said that the bank educates customers and encourages them 

to obtain cash at the point of sale so that they do not incur ATM fees and 

the bank can have a smaller ATM fleet. However, as previously 

discussed, these options may not be available to all consumers, and we 

do not know the extent to which consumers obtain cash at the point of 

sale or receive ATM fee refunds.

ATM operators incur a variety of costs—including rent to place the 

machines in retail locations and security costs to keep the machines safe, 

among others—and the amount of these costs varies widely among 

operators. ATM operators report taking a number of steps to respond to 

changing operating costs, such as increasing surcharge fees and 

investing less money in ATMs. However, operators also anticipate that 

many of these costs will rise in the future.

 

37Twenty-six financial institutions—9 large banks, 9 credit unions, and 8 midsize banks—

responded to this question and reported a total of 12,701 branded ATMs.

ATM Operators Have 

Varying Costs, and 

Many Operators 

Anticipate Costs Will 

Rise
 

Page 23 GAO-13-266 Automated Teller Machines

ATM operators incur a wide variety of costs in providing ATM services. 

Our survey of a judgmental sample of the 10 largest banks and credit 

unions, 10 randomly selected midsize banks (“financial institution” 

operators), and 4 large independent ATM firms (“independent” operators) 

collected information on the following cost categories, all of which—

except bank sponsorship—are typically borne by both financial institution 

and independent ATM operators.38

• Rent. Financial institution operators pay rent for ATM facilities at 

locations not in an institution facility, and independent operators pay 

rent for retail or other locations, such as grocery stores or gas 

stations.39

• Hardware and software investments. Operators purchase, install, and 

upgrade ATM software and equipment, including the ATM terminals 

and physical security equipment, such as bolting devices which 

secure the machines to walls or the floor.

• Cash services. Operators must take steps to ensure that ATMs are 

adequately stocked with cash and, therefore, spend time and 

resources monitoring transaction levels in order to accurately forecast 

future cash needs. Cash is delivered to the ATM via armored carrier. 

Independent operators also need to pay to access a supply of cash 

from a bank vault.

• Maintenance and repairs. Maintenance includes cleaning the 

machinery, making routine repairs, and restocking of supplies (such 

as receipt paper), as well as more significant repairs, which can incur 

higher costs for tools, parts, and labor.

 

38As previously discussed, independent ATMs may be owned by merchants, not the 

independent operators, and in those cases, the merchant-owners bear some of the ATM 

operational costs. We developed the cost categories and their content by reviewing 

various reports and studies on ATM operations, as well as a Federal Reserve survey 

recently deployed on debit card processing costs. We then received input on the 

categories from knowledgeable industry representatives and staff from the Federal 

Reserve and CFPB. For a detailed discussion of the costs survey methodology, see 

appendix I. 

39In some cases, in lieu of rent, the ATM operator shares a portion of fee revenues with 

the merchant as part of a revenue-sharing arrangement.

Financial Institution and 

Independent ATM 

Operators Have a Variety 

of Disparate Costs
 

Page 24 GAO-13-266 Automated Teller Machines

• Physical security and insurance. Physical security costs are those 

incurred to keep the ATM and the surrounding lobby or area safe and 

include items such as lighting and cameras. Insurance costs include 

those policies that cover the cash in the machines.

• Infrastructure and processing. Operators need to install and maintain 

the telecommunications infrastructure necessary for ATM operations 

and transaction processing. Processing costs include fees associated 

with transaction processing (switch fees) and costs associated with 

interbank settlement and account posting.

• Network fees. ATM operators pay membership or license fees to the 

EFT networks in order to route transactions on the networks.40

Network fees also include any fees the ATM operator pays for 

membership in one or more surcharge-free networks.

• Taxes and licenses. In addition to property and sales taxes, ATM 

operators are sometimes required to pay for state and local licenses, 

on either a one-time or recurring basis.

• Regulatory and compliance costs. Regulatory and compliance costs 

include paying for the required ATM signage alerting customers to any 

fees, as well as the costs of regulatory inspections and reviews.41

• Fraud prevention and fraud losses. Fraud prevention costs are those 

related to activities aimed at detecting and preventing ATM fraud. 

Fraud losses are those incurred by the ATM operator when fraud 

occurs, including cash theft and ATM robberies.42

• Bank sponsorship. Bank sponsorship is a cost borne only by 

independent ATM operators, which, as previously discussed, must 

 

40Independent ATM operators typically pay these network fees to their sponsoring bank, 

which is the entity with the membership in the EFT network.

41As previously discussed, until December 2012, the Electronic Fund Transfer Act 

required ATM operators that charge a fee to post physical notice of that fee on the ATM 

terminal; the revised statute requires only the on-screen notification. 15 U.S.C. § 

1693b(d)(3)(B) (2013), amended by Pub. L. No. 112-216, 126 Stat. 1590 (2012).

42In the survey we asked the ATM operators to report their “net” fraud losses, which are 

total fraud losses, minus any offsets from insurance payments or other sources.
 

Page 25 GAO-13-266 Automated Teller Machines

have a financial institution that sponsors their membership in the EFT 

networks.

ATM operators we surveyed and spoke with indicated that key drivers of 

operating costs varied. For example, in our survey, large banks reported 

much higher costs for some categories, as a percentage of total costs, 

than did midsize banks and credit unions. Likewise, in some cost 

categories there was a wide range of reported per-ATM costs, while in 

other categories, the per-ATM costs were fairly consistent. None of the 

data we collected on costs are generalizable to either the financial 

institution or independent ATM operator populations at-large, although 

some costs, such as hardware and software investments, were 

mentioned as key drivers by many of the operators included in our work.

Our analysis of the data collected from a sample of 30 institutions from 

three financial institution types—large bank, medium bank, and credit 

union—revealed some key differences in the biggest cost drivers for 

these ATM operators.43 The large banks’ costs for hardware and software 

investments were much higher as a percentage of their total costs than 

for midsize banks and credit unions in our survey. As shown in figure 5, 

the majority (63 percent) of the larger banks’ costs were for hardware and 

software investments and upgrades. The second most prominent cost for 

the large banks was rent (15 percent of overall costs), followed by 

maintenance and repair (9 percent of overall costs) and cash services (6 

percent of overall costs). In contrast, the hardware and software 

investments were a much smaller percentage of reported total costs for 

the midsize banks (18 percent) and credit unions (23 percent) in our 

survey.44 In addition, midsize banks and credit unions that participated in 

our survey had much more even proportions of spending across the 

various cost categories. Midsize banks and credit unions also reported 

that a greater percentage of total costs were dedicated to infrastructure 

 

43As previously discussed, we received responses from 9 out of 10 large banks, 8 out of 

10 midsize banks, and 9 out of 10 credit unions, but response rates varied by question.

44There may be several reasons why the large banks’ percentage of costs dedicated to 

hardware and software is higher than the other two financial institution types included in 

our survey. Industry sources and representatives we interviewed indicate that several of

the largest banks are updating their ATM fleets with new, more expensive terminals, and 

these major investments may be one reason for greater hardware and software costs. 

Key Operating Costs 

Varied across Different 

ATM Operators

Financial Institution ATM 

Operators 
 

Page 26 GAO-13-266 Automated Teller Machines

and processing (17 and 23 percent respectively), compared to the large 

banks (2 percent).45

Figure 5: Top Five Costs Borne by Financial Institution ATM Operators in GAO Survey, as a Percentage of Reported Total 

Costs

a

This category includes capitalized and noncapitalized costs.

In some cost categories institutions reported a wide range of per-ATM 

costs across the three financial institution types, while in other categories, 

the per-ATM costs were fairly consistent. For example, the financial 

institutions we surveyed reported that per-ATM costs in calendar year 

2011 for rent and hardware and software were much higher for the large 

banks than for the credit unions and midsize banks. The average rent 

cost, on a per-ATM basis, was $27,173 for large banks, $4,935 for 

 

45According to knowledgeable financial regulatory staff we spoke with, one possible 

reason the large banks in our survey reported incurring less in infrastructure and 

processing costs, as a percentage of total costs, might be because they often do 

processing services in-house. Processors that perform similar services for other financial 

institutions on an outsourced basis may bundle those costs with other services or charge 

more. 
 

Page 27 GAO-13-266 Automated Teller Machines

midsize banks, and $4,032 for credit unions.46 We saw similar results for 

hardware and software investments, with large banks reporting, on 

average, $28,607 in costs per ATM, while midsize banks’ and credit 

unions’ average costs were, respectively, $3,642 and $7,422.47 These 

hardware and software costs include both capitalized and noncapitalized 

items, although not all institutions reported noncapitalized costs.48 In 

contrast, the costs for maintenance and repairs were much closer in 

range for the three financial institution types. The average maintenance 

and repair cost, on a per-ATM basis, was $5,444 for large banks, $3,485 

for midsize banks, and $5,827 for credit unions.49

In some cost categories credit unions reported higher costs than their 

bank counterparts—cash services, and infrastructure and processing. 

The average cost for cash services, on a per-ATM basis, was $6,847 for 

credit unions, $3,765 for midsize banks, and $3,495 for large banks.50

Similarly, the average cost for infrastructure and processing, on a perATM basis, was $7,958 for credit unions, $3,494 for midsize banks, and 

$1,191 for large banks.51 In contrast, credit unions’ costs for network fees 

were significantly lower than those of the banks, with an average cost, on 

a per-ATM basis, of $150 for credit unions, $331 for large banks, and 

 

46Response rates for this question were: 6 out of 10 large banks, 6 out of 10 midsize 

banks, and 8 out of 10 credit unions. In the survey we defined rent costs as: the amount 

paid for ATM facilities at off-premise locations (not in a bank or credit union facility); and 

the amount of any revenues shared (partially or entirely) with a merchant or other party for 

ATM facilities at that location or locations. Some revenue-sharing arrangements are 

based, partially or entirely, on transaction levels, so as the number of transactions 

increases, so do rent costs. For a full description of each cost category, as well as 

average per-ATM costs, see table 11 in appendix II. 

47Response rates for this question were: 6 out of 10 large banks, 7 out of 10 midsize 

banks, and 8 out of 10 credit unions. 

48For a break-out of capitalized and noncapitalized hardware and software costs, see 

table 11 in appendix II. 

49Response rates for this question were: 5 out of 10 large banks, 8 out of 10 midsize 

banks, and 8 out of 10 credit unions. 

50Response rates for this question were: 5 out of 10 large banks, 7 out of 10 midsize 

banks, and 8 out of 10 credit unions. 

51Response rates for this question were: 4 out of 10 large banks, 6 out of 10 midsize 

banks, and 7 out of 10 credit unions. 
 

Page 28 GAO-13-266 Automated Teller Machines

$340 for midsize banks.52 For more information on average per-ATM 

costs across the three types of operators in all cost categories, see 

appendix II.

Community bankers we interviewed reported that their leading costs were 

investments in hardware and software, largely to upgrade older machines 

for compliance with Americans with Disabilities Act (ADA) requirements, 

or to purchase new machines all together.53 Specifically, one 

representative told us his bank spent more than $52,000 to upgrade the 

software in the bank’s 26 ATMs, a cost of approximately $2,000 per 

machine. The community bankers noted that while the newer machines 

are more expensive, they offer the customer more functionality and value 

due to their enhanced capabilities, such as being able to scan and 

deposit checks. The other prevalent costs for the community bankers 

were fraud (prevention efforts and losses), repairs, processing, and 

network fees.

Cost data are more limited for independent ATM operators, making 

identifying key costs difficult. One large independent ATM firm that we 

surveyed reported that its top five calendar year 2011 per-ATM costs (as 

a percentage of all costs) were (1) rent, (2) infrastructure and processing, 

(3) cash services, (4) hardware and software investments, and (5) bank 

sponsorship costs. Meanwhile the smaller firm that we surveyed reported 

that its top five calendar year 2011 costs (as a percentage of total costs) 

were (1) hardware and software investments, (2) maintenance and 

repairs, (3) cash services, (4) infrastructure and processing, and (5) 

 

52Response rates for this question were: 4 out of 10 large banks, 6 out of 10 midsize 

banks, and 6 out of 10 credit unions. 

53The new ADA requirements for ATMs required operators to add certain audio and touchbased technologies that assist vision-impaired consumers. These new requirements were 

announced in 2010, when the Department of Justice issued revised rules for Title III of the 

Americans with Disabilities Act of 1990, which prohibits discrimination on the basis of 

disability and requires commercial facilities to be designed, constructed, and altered in 

compliance with certain accessibility standards. Pub. L. No.101-336, 104 Stat. 327 (1990), 

(codified at 42 U.S.C. §§ 12101-12213). Building on the 1991 ADA standards that required 

ATMs to be accessible to individuals using wheelchairs, the Department of Justice’s 2010 

standards added specific technical requirements to ATMs for speech output, privacy and 

tactilely-discernible input controls, among other things. 28 C.F.R. § 36, Appendix B. ATM 

operators were required to have completed required upgrades by March 15, 2012. 75 Fed. 

Reg. 56, 236, 56,254 (Sept. 15, 2010).

Independent ATM Operators
 

Page 29 GAO-13-266 Automated Teller Machines

rent.54 In addition to the cost information gathered through the survey, we 

interviewed two small independent ATM firms, and—like the two firms 

that participated in the survey—they told us their key costs included cash 

services and processing, among others. In addition, we interviewed 

officials from another large independent firm who provided us with cost 

data that indicated that the firm’s top costs for calendar year 2011 were 

rent, cash services, and maintenance and repair.55

Most operators included in our study—financial institutions and 

independent firms—reported that overall ATM costs have increased over 

the past 5 years and they expect that they will continue to do so. Ten 

financial institutions we surveyed reported that per-ATM costs had 

significantly increased in the past 5 years, ten reported costs had slightly 

increased, and five reported costs remained about the same.56 The cost 

drivers most frequently cited by survey respondents were upgrading to 

more versatile ATMs—with functions such as check-imaging—complying 

with ADA requirements, and upgrading software.57 Other cost drivers the 

financial institution representatives reported were increasing fraud 

prevention efforts, adding ATMs to their fleets, and paying more in 

network fees.58 As previously discussed, the community bankers we 

interviewed also indicated that ATM upgrades to comply with ADA 

 

54Given the small number of independent operators that participated in our survey—two 

out of four firms—what we can report without revealing the identity of a given firm is 

limited, and therefore we are not able to provide specific dollar amounts for the cost 

categories. In addition, these data are not representative of independent ATM operators in 

general. 

55Although we interviewed officials from this firm and they submitted cost and revenue 

information to us, they did not complete the survey. Therefore we cannot compare this 

firm’s reported costs with those of the survey respondents directly because we are not 

assured that the categories are similar enough. 

56Four financial institutions did not respond to the question, and one reported “no opinion.” 

57In addition to asking the respondents to classify the level of cost increases or decreases, 

we asked an optional follow-up question—to describe the changes in operating costs and 

the reasons why. We then analyzed those responses and grouped them into like 

categories. Thirteen operators cited upgrading to more versatile ATMs as a major cost 

driver, eight cited compliance with ADA requirements, and six cited software upgrades. 

For more information about our content analysis of narrative responses, see appendix I.

58Four operators cited fraud prevention efforts as a reason why costs increased, three

operators cited adding ATMs to their fleets, and two cited increases in network fees. 

Increasing Costs and 

Declining Revenues Are 

Prompting Some Changes 

in ATM Operations
 

Page 30 GAO-13-266 Automated Teller Machines

requirements were a leading cost driver in calendar year 2011, and some 

said network costs had increased as well over the past 5 years. The two 

independent operators in our survey reported their costs had increased 

slightly over the past 5 years. One operator noted higher manufacturing 

costs as a driver and the other reported an increase in fuel prices (which 

increases the costs to transport cash to the terminals via armored carrier). 

The two independent operators we interviewed also said their overall 

costs have risen in the past 5 years, for armored carrier services and 

network fees. They also reported increased rent costs, among others. 

Some of the operators noted that the costs associated with certain 

actions could yield future savings. For example, while the cost of 

purchasing the newer machines has increased, those ATMs have 

improved technology, so service costs have declined. Similarly, one 

operator reported that with the expanded function of deposit-imaging, the 

newer ATMs have reduced paper costs.

Many of the operators told us that during that same 5-year period, where 

costs have increased, ATM revenues have decreased. As previously 

discussed, ATM operators collect revenues from fees charged during 

some ATM transactions. In our survey, 14 financial institution operators 

reported that their per-ATM revenues had decreased—6 said they had 

done so significantly, and 8 said slightly. In contrast, 6 operators reported 

that revenues remained about the same, and 4 reported a slight increase 

during that same period.59 The most frequently cited reason the operators 

gave for the decreased revenues was declining transaction volumes—

both overall and among non-account holders, who typically would 

generate income for the ATM operator through surcharge fees. Some

financial institution operators stated that transaction levels are down due 

to the greater availability of surcharge-free networks and consumers 

obtaining cash at point-of-sale transactions, among other things. Several 

of the community bankers we spoke with expressed similar views that 

ATM revenues, along with transaction levels, have decreased generally 

over the past 5 years. The two independent operators in our survey 

reported their revenues had significantly decreased over the past 5 years, 

but cited reductions in their interchange fee revenues as a primary factor. 

The two smaller independent firms we interviewed reported similar issues 

with reduced interchange revenues.

 

59Twenty-six financial institution operators responded to the question, including two 

operators that answered “no opinion.” 
 

Page 31 GAO-13-266 Automated Teller Machines

Looking forward, many of the operators indicated they expect that costs 

would continue to rise and that revenues would remain flat or decline in 

the future. For example, our survey results showed that 18 out of 25

financial institution operators anticipate ATM costs will increase in the 

future. The main drivers cited for these future increases are further 

investments in new and enhanced ATM terminals or upgrades that will be 

needed in order to comply with new or enhanced industry wide data 

security standards.60 The community bankers and one independent firm 

we interviewed expressed similar views that ATM costs will continue to 

rise. Similarly, of the ten financial operators that addressed future 

revenue trends in our survey, seven indicated they anticipate a decline, 

due primarily to fewer transactions. Likewise, one of the two independent 

firms that participated in our survey also said it anticipates future 

revenues will be flat.

ATM operators reported taking various steps to adapt to the rise in costs 

and decline in revenues. For example, two credit unions reported in our 

survey that they recently raised their surcharge fee amounts in response 

to rising costs. Another credit union reported it was being more prudent in 

placing ATMs in new locations by first performing extensive evaluation of 

traffic flows, surrounding competition, and associated costs before 

committing to a new location. One of the large banks noted that because 

average revenues per ATM will likely continue to decline as consumers 

continue to avoid incurring surcharges, the bank would focus more on 

serving its own customers with ATM placements. Finally, some of the 

community bankers we interviewed said that as ATM transaction levels 

decline, so will their investments in ATMs. The owner of one one 

independent ATM firm we interviewed told us that independent operators 

need to seek opportunities to diversify their portfolio of ATM services, 

such as establishing or expanding branding partnerships in order to 

increase revenues. He also noted that maximizing the number of 

 

60All participants in the EFT networks, including ATM operators, are required to meet 

certain industry-wide data security standards established by the Payment Card Industry 

Security Standards Council. These requirements include installing and maintaining 

systems to protect cardholder data and that ATMs include the use of approved encrypted 

personal identification number pads. Also, the U.S. ATM and debit point-of-sale markets 

are moving in the direction of new cards (“chip cards”) that use an embedded chip 

microprocessor for payment transactions, as opposed to the current magnetic stripe 

technology. As publicly announced, by 2017, MasterCard and VISA will shift liability for 

fraudulent transactions to whichever party has not adopted the chip card technology, so 

many ATM operators told us they will be updating their ATMs to accept the new cards.
 

Page 32 GAO-13-266 Automated Teller Machines

transactions on a per-ATM basis will be important. One large independent 

firm reported in the survey that as interchange fees and resulting 

revenues decrease, merchants—in those cases where they set fees—will 

increase the surcharge amounts to make up the difference. However, as 

we previously discussed, there are many factors taken into account when 

setting fees, and several of the operators told us that setting fees too 

high, above neighboring competitors, could discourage consumers from 

using their ATMs.

We provided a draft of this report to CFPB, FDIC, the Federal Reserve, 

NCUA, and OCC for their review and comment. CFPB, the Federal 

Reserve, NCUA, and OCC submitted technical comments which were 

incorporated where appropriate.

We are sending copies of this report to CFPB, FDIC, the Federal 

Reserve, NCUA, and OCC, interested congressional committees, 

members, and others. In addition, this report will be available at no 

charge on our website at http://www.gao.gov.

Should you or your staff have questions concerning this report, please 

contact me at (202) 512-8678 or cackleya@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. Key contributors to this report are listed in 

appendix IV.

Alicia Puente Cackley

Director

Financial Markets and

 Community Investment

Agency Comments
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-13-266 Automated Teller Machines

This report reviews the fees paid by consumers when conducting 

automated teller machine (ATM) transactions, as well as the costs borne 

by ATM operators in providing those services. Specifically, the objectives 

of this report are to discuss (1) the business models for ATM operators—

financial institution and independent firms—and how they set ATM fees, 

(2) the amounts of fees that consumers incur to conduct ATM 

transactions and how these fees changed over time, and (3) the reported 

costs of ATM operations for financial institution and independent ATM 

operators and how costs and revenues are expected to change.

To understand the history of ATMs, how ATM transactions are processed, 

and requirements for ATM operators, we reviewed prior GAO, regulatory, 

and industry reports on ATM fees and operations, and we interviewed 

relevant officials from the Board of Governors of the Federal Reserve 

System (the Federal Reserve), the Federal Deposit Insurance 

Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), 

the National Credit Union Administration (NCUA), and the Bureau of 

Consumer Financial Protection, commonly known as CFPB. In addition, 

we interviewed officials from five associations: American Bankers 

Association (ABA) and the Independent Community Bankers of America 

(ICBA), which represent various sectors of the banking industry; the 

National ATM Council and the ATM Industry Association (ATMIA), which 

represent independent ATM operators; and U.S. PIRG, a federation of 

independent, state-based, citizen-funded organizations that advocate for 

consumer interests. We also interviewed representatives from two

national banks, a credit union, one large independent ATM firm, three 

electronic funds transfer (EFT) networks, and a financial institution that 

sponsors independent ATM operators.

In order to gather information on ATM costs and operations for smaller 

financial institutions and independent ATM firms, we conducted two group 

interviews with representatives from nine community banks and two 

interviews with smaller independent ATM firms. We identified these firms 

with assistance from ABA, ICBA, and ATMIA. In addition, we relied on 

information provided to us by ATMIA that described the composition of 

the independent operator market—specifically, the percentage of ATMs 

owned by operators versus those operated by merchants. This 

information could not be corroborated because no comparable data were 

available, either publicly or from the financial regulators and other industry 

sources we asked. However, we determined that our use of the 

information from ATMIA was appropriate because it is used to describe 

the independent ATM market and provide context.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-13-266 Automated Teller Machines

To discuss the operations and costs for ATM operators, in addition to the 

interviews discussed above, we surveyed a nonprobability sample of 

financial institutions and independent firms that operate ATMs to collect 

information on

• ATM operations and business models,

• ATM transaction levels for calendar year 2011,

• ATM costs for calendar year 2011 in 12 specific cost categories,

• overall ATM cost and revenue trends for the past 5 years and in the 

future, and

• factors ATM operators consider when setting ATM fees.

In order to gain cost and operational information from ATM operators of 

various sizes, we deployed a survey to the 10 largest banks and 10 

largest credit unions (by asset size), 10 randomly selected midsize banks 

(with assets between $10 billion and $50 billion), and 4 large independent 

ATM firms (with 10,000 or more ATMs in their portfolios). To select the 

banks, we used data from SNL Financial—a private financial database 

that contains publicly filed regulatory and financial reports.1 We eliminated 

those that did not offer personal checking account services, as well as 

any online banks, since they generally do not maintain substantial 

numbers of ATMs. To select the credit unions, we obtained a list of the 

largest credit unions, by asset size, from NCUA. Because none of the 

regulators and business associations we spoke with were able to provide 

data on the total population of independent ATM operators, and no data 

are publicly available, we relied on estimates provided to us by one of the 

largest independent operators as to the size and geographic locations of 

the independent firms in the industry. We used that list to select the firms 

and were able to verify the information provided only in the cases where 

the firm responded to the survey.

For the survey questionnaire, we developed 12 categories (11 applied to 

all operators, and 1 was a cost incurred only by independent ATM 

operators) in order to capture information on a broad range of ATM 

operational costs. After we drafted our initial cost categories, we asked for 

comments from knowledgeable officials at the Federal Reserve, CFPB, 

ABA, and a consulting firm that works extensively with the independent 

ATM industry. We conducted six pretests to verify that (1) the questions

 

1

We ran our data reports from SNL on May 7, 2012, so the asset rankings were as of that 

date. 
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-13-266 Automated Teller Machines

were clear and unambiguous, (2) terminology was used correctly, (3) the 

questionnaire did not place an undue burden on respondents, (4) the 

information could feasibly be obtained, and (5) the survey was 

comprehensive and unbiased. We chose the six pretest institutions to 

include various sizes of ATM operators: two large banks, one large credit 

union, one midsize bank, and one large and one small independent ATM 

firm. We conducted the pretests over the telephone. We made changes to 

the content and format of the questionnaire after each of the six pretests, 

based on the feedback we received. For additional quality control, an 

independent evaluator within GAO also reviewed a draft of the 

questionnaire prior to its administration. Furthermore, we determined—

based on the pretest with the smaller independent ATM firm—that the 

questionnaire would be overly burdensome for smaller firms to complete, 

potentially leading to minimal participation. For this reason, we limited our 

independent ATM firm sample population to firms with 10,000 or more 

ATMs.

We sent the questionnaire by e-mail in an attached PDF form that 

respondents could return electronically after marking check-boxes or 

entering responses into open answer boxes. Alternatively, respondents 

could return the questionnaire by mail after printing the completed form.

Through e-mails and phone calls in advance of the questionnaire, we 

determined the best contact at each financial institution or independent 

firm. We e-mailed the questionnaire with a cover letter to financial 

institutions between July 31 and August 1, 2012, and independent ATM 

firms between September 5 and September 11, 2012. Three weeks later, 

we sent a reminder e-mail to everyone who had not responded. We 

telephoned all respondents who had not returned the questionnaire after 

4 weeks and asked them to participate. Completed questionnaires were 

accepted until September 28, 2012, for financial institutions and October 

31, 2012, for the independent ATM firms.2

Questionnaires were completed by 9 out of 10 large banks, 9 out of 10 

credit unions, 8 out of 10 midsize banks, and 2 out of 4 independent ATM 

firms. However, the number of respondents varied by question. 

Specifically, three large banks and one credit union completed sections of 

the questionnaire on ATM transaction levels and overall cost and revenue 

 

2

We accepted one additional survey questionnaire submitted by a financial institution on 

October 15, 2012, after the formal deadline. 
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-13-266 Automated Teller Machines

trends, but did not submit dollar amounts for the cost categories. As 

previously discussed, we made multiple contacts by telephone and e-mail 

to nonresponding institutions, but one large bank, one credit union, two 

midsize banks, and two of the independent ATM firms declined to 

participate.

The practical difficulties of conducting any survey may introduce errors, 

commonly referred to as nonsampling errors. For example, difficulties in 

interpreting a particular question, sources of information available to 

respondents, or data analysis can introduce unwanted variability into the 

survey results. We took steps in developing the questionnaire, and in 

collecting and analyzing the data, to minimize such nonsampling error. 

Almost all responses from the PDF forms were directly read into a data 

file, and two analysts independently verified that all information provided 

in the forms was read in correctly. For the two forms that could not be 

read into the file, one analyst keypunched the responses and another 

verified the entries. All data analysis programs were independently 

verified for accuracy.

We were not able to independently verify the cost information submitted 

by survey respondents. However, during the pretests and in the survey 

questionnaires we asked the respondents to tell us what sources they 

would or did use in calculating the costs they reported. Commonly cited 

data sources for the costs included internal accounting reports and billing 

statements from external third-parties, such as processors. Based on the 

information provided on the cost data sources and follow-up calls with 

survey respondents, we determined the data they reported were 

sufficiently reliable for our purposes.

Using the data provided by the survey respondents, we calculated the 

number and type of ATM transactions in calendar year 2011, the 

percentage of total costs represented by each cost category, and the 

average per-ATM costs for each category. Due to the sensitive and 

possibly proprietary nature of the information we collected with the 

survey, we aggregated the cost data at a high level and presented it in a 

way that prevents individual organizations from being identified. For the 

four questions that asked about past and future cost and revenue trends, 

as well as the factors the operators take into account when setting fees, 

we performed a content analysis. Specifically, we analyzed the responses 

for each question and then grouped them into like categories. A second 

evaluator reviewed the categories to ensure that we were consistent in 

our coding. In any instance where the second reviewer disagreed with a 

categorization, team members met to discuss the categories and reached 
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-13-266 Automated Teller Machines

consensus on the final category assignment for each response. The

numbers of responses in each content category were then summarized 

and tallied. For more detailed information on the survey results, see 

appendix II.

To report on the amounts of fees that consumers pay to conduct 

transactions at financial institution ATMs, and how these fees changed 

over time, we purchased and analyzed data on surcharge and foreign 

ATM fees charged by banks and credit unions from 2007 through 2012 

from Moebs $ervices, Inc. (Moebs), a market research firm that 

specializes in the financial services industry. Moebs collected its data 

through telephone surveys with financial service personnel at each 

sampled institution. In the surveys, callers used a “mystery shopping” 

approach and requested rates and fees while posing as potential 

customers. The statistical design of the survey for each year consisted of 

a stratified random sample by (1) institution type, (2) institution size, and 

(3) regions of the country defined by metropolitan statistical area and 

state.3

The surveys were completed in June for each of the years we requested, 

except for 2010, when the survey was completed in July. Table 3 shows 

the number of financial institutions for which we obtained data.

Table 3: Number of Financial Institutions Surveyed by Moebs $ervices, 2007-2012

2007 2008 2009 2010 2011 2012

Number of institutions surveyeda 2,030 2,041 2,041 2,243 2,532 2,776

Source: GAO analysis of Moebs $ervices data.

a

The number of institutions sampled each year varied because of changes to the number of cities and 

states surveyed, changes in the overall number of financial institutions, and refining the accuracy and 

precision of the sample selection.

Using the Moebs data, we computed weighted estimates and 95 percent 

confidence intervals of the percentage of institutions charging surcharge 

 

3

A metropolitan statistical area (metro area) is a geographic entity defined by the Office of 

Management and Budget for use by federal statistical agencies in collecting, tabulating, 

and publishing federal statistics. A metro area contains a core urban area population of 

50,000 or more. Each metro area consists of one or more counties and includes the 

counties containing the core urban area, as well as any adjacent counties that have a high 

number of residents who commute to work within the urban core. 
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-13-266 Automated Teller Machines

and foreign fees and weighted averages and medians of these fees. All 

percentage estimates presented in this report have a margin of error of 

+/- 5 percentage points or fewer, and all average and median estimates 

have a relative margin of error of +/-5 percent or less, unless otherwise 

noted. All differences between estimated values identified in this report 

are statistically significant at the 95 percent confidence level (p-value <= 

0.05), unless otherwise noted. We also examined the differences 

between the estimated prevalence and average fees for type and size of 

financial institution, as well as geographic region and type of location of 

the financial institution separately. We did not conduct a multivariate 

analysis using all of these factors, control for all factors at once, or control 

for additional factors in our analysis. To evaluate trends in ATM fees, we 

adjusted the numbers for inflation to remove the effect of changes in 

prices. The inflation-adjusted estimates used a base year of 2012 and 

Consumer Price Index calendar year values as the deflator. We reviewed 

interviews and analysis from our previous work on bank fees to 

understand Moebs’ methodology for collecting the data and ensuring its 

integrity. In addition, we conducted reasonableness checks on the data 

we received and identified any missing, erroneous, or outlying data. We 

also worked with Moebs representatives to ensure our analysis of their 

data was correct. We determined that the Moebs data were reliable for 

the purposes of this report.

Since data on ATM fees charged by independent operators were not 

available, we engaged the services of another market research firm—

Informa Research Services (Informa)—to conduct “mystery shops” at 100 

judgmentally selected independent ATMs. We selected 10 ATMs in each 

of the top 10 metropolitan statistical areas. In order to ensure we captured 

fee information from a wide variety of locations frequented by consumers 

on a regular basis, we directed Informa to choose ATM locations that 

covered the following types of stores: drug stores, grocery stores, gas 

stations/convenience stores, and liquor stores. We excluded ATMs at 

airports or casinos—locations where most consumers would not go on a 

regular basis and for which, according to market research, there is 

typically a higher fee. We also excluded ATMs at supermarket chains that 

were likely to have a bank branch or an ATM operated by a bank or credit 

union on the premises because the focus of this part of our study was 

ATM fees charged by independent operators. Prior to making the final 

selections, Informa contacted the locations and verified that the ATMs 

were nonbank operated and that they were in working order. Locations 

having bank-operated or branded ATMs or machines that were not 

working were replaced with locations having independent and functioning 

ATMs in the same neighborhood, or as close as possible.
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-13-266 Automated Teller Machines

The mystery shop process involved having the shoppers go to each 

selected ATM and use their own debit card to conduct a transaction. The 

shopper documented (1) the surcharge fee amount that was posted on 

the ATM, (2) the surcharge fee amount that appeared on the screen after 

the transaction was begun, and (3) the surcharge fee amount printed on 

his or her receipt. The mystery shoppers entered this information into an 

online database. In addition, the shoppers took pictures of the ATM, 

screen, and their receipt, which Informa staff used to verify that shoppers 

correctly recorded the fee information and that the correct images were 

attached to the correct responses. Finally, the receipts were double 

checked against the location addresses to ensure that the shoppers 

visited the correct ATM. We then analyzed the data we obtained from 

Informa and computed the average surcharge fees charged to mystery 

shoppers for ATMs included in the sample. These data indicate what 

independent ATM fees were on a particular day in 2012 at those 100 

ATMs and are not generalizable to the population of independent ATMs in 

the United States.

We reviewed documentation submitted by Informa to understand their 

methodology for collecting the data and ensuring their integrity. We 

conducted reasonableness checks on the data we received and identified 

10 mystery shoppers who did not report a fee printed on their ATM 

receipt. We instructed Informa to conduct follow up on these cases, which 

included checking to see if the mystery shopper used a card that was part 

of a surcharge-free network, and in certain cases, to send an additional 

mystery shopper to the ATM. We also worked with Informa 

representatives to ensure our analysis of their data was correct. We 

determined that Informa’s data were reliable for the purposes of this 

report.

We conducted this performance audit from November 2011 to April 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Selected Results from GAO’s 

Survey on ATM Operator Costs and Operations

Page 40 GAO-13-266 Automated Teller Machines

This appendix presents selected results from GAO’s survey on ATM 

operator costs and operations. We surveyed financial institution and 

independent ATM operators to collect information on their business 

operations and models, costs, and transaction levels for calendar year 

2011, and what factors they take into account when setting fees. The 

survey was deployed to the 10 largest banks and credit unions (by asset 

size) and 10 randomly selected midsize banks (with assets between $10 

billion and $50 billion).1 We designed and deployed a separate survey to 

four independent ATM operators that operate 10,000 or more ATMs, and 

we received responses from two.2 We were not able to independently 

verify the cost information submitted by survey respondents. However, we 

asked the respondents to tell us what sources they used in calculating the 

costs they reported. They relied on sources such as internal accounting 

reports and third-party bills. Based on the source information provided 

and follow-up call with survey respondents, we determined the data they 

reported were sufficiently reliable for our purposes. None of the costs or 

operations data we collected are generalizable to ATM operators at-large.

Table 4 summarizes the number and size of financial institution ATM 

operators that participated in our survey, as well as the number of ATMs 

they were operating as of December 31, 2011.

Table 4: Financial Institution ATM Operators in GAO Survey

Type of financial institutiona Number

Number of ATMs

(as of December 31, 2011) 

On-site Off-site Branded Total

Large banks 9 44,669 19,866 11,895 76,430

Midsize banks 8 1,203 863 6 2,072

Large credit unions 9 924 1,607 800 3,331

Total 26 46,796 22,336 12,701 81,833 

Source: GAO analysis.

a

We deployed the survey to the 10 largest banks (by asset size), 10 randomly selected midsize banks 

(with assets between $10 billion and $50 billion), and the 10 largest credit unions (by asset size).

 

1

We received survey responses from 9 out of 10 large banks, 8 out of 10 midsize banks, 

and 9 out of 10 credit unions, although response rates varied by question. 

2

For more information on the survey methodology, see appendix I. 

Appendix II: Selected Results from GAO’s 

Survey on ATM Operator Costs and 

Operations
Appendix II: Selected Results from GAO’s 

Survey on ATM Operator Costs and Operations

Page 41 GAO-13-266 Automated Teller Machines

We collected similar information from independent ATM operators. In 

addition to owning and operating their own ATMs, independent ATM firms 

offer a wide range of ATM-related services to merchants and other 

entities that own ATMs, such as monitoring and maintaining appropriate 

cash levels in terminals and processing transactions. There are four 

primary business models for independent ATM operators; therefore our 

survey asked for information on the number of ATMs for each model. In 

both the “turnkey” and “merchant-assisted” business models, the 

independent operator owns the ATM. In the turnkey model, the operator 

is responsible for most aspects of the ATM’s operations, while the 

merchant is responsible only for providing a place to locate the ATM and 

the electricity to operate it. The merchant-assisted model is similar to 

turnkey, but the merchant provides and loads cash into the machines, as 

well as provides basic maintenance. In the “merchant-owned and loaded” 

and “merchant cash-assisted” models, the merchant owns the ATM and is 

responsible for many of the operations. However, in the merchant ownedand loaded model, the merchant manages and loads cash into the ATM, 

while in the merchant cash-assisted model, the independent operator 

handles those tasks. Table 5 summarizes the number of independent 

ATM operators that participated in our survey, as well as the number of 

ATMs they were operating under each business model as December 31, 

2011.

Table 5: Independent ATM Operators in GAO Survey

Number

Number of ATMs

(as of December 31, 2011)

Turnkey

MerchantassistedMerchant-owned 

and loaded

Merchant

cash-assisted Total

Independent ATM Operators 2 858 346 64,032 534 65,770

Source: GAO analysis.

Tables 6 through 10 summarize the reported number and types of 

calendar year 2011 ATM transactions for the financial institutions and 

independent ATM operators that participated in our survey.
Appendix II: Selected Results from GAO’s 

Survey on ATM Operator Costs and Operations

Page 42 GAO-13-266 Automated Teller Machines

Table 6: Number and Types of ATM Transactions Reported by All Financial Institutions in GAO Survey, Calendar Year 2011

Transaction type

Number incurring

a surcharge 

Percentage 

incurring

a surcharge

Number

not incurring

a surcharge 

Percentage

not incurring

a surcharge Total

Cash withdrawals 274,490,626 14.11% 1,670,724,011 85.89% 1,945,214,637

Balance inquiries 333,064 0.05 613,376,064 99.95 613,709,128

Deposits 2,891 0.00 586,040,519 100.00 586,043,410

Fund transfers 13,827 0.03 49,035,169 99.97 49,048,996

Denials 37,696 0.06 63,904,257 99.94 63,941,953

All other transactions 48 0.00 26,667,071 100.00 26,667,119

Total transactions 274,878,152 8.37% 3,009,747,091 91.63% 3,284,625,243

Source: GAO analysis.

Table 7: Number and Types of ATM Transactions Reported by Large Banks in GAO Survey, Calendar Year 2011

Transaction type

Number incurring

a surcharge 

Percentage 

incurring

a surcharge

Number

not incurring a 

surcharge 

Percentage not 

incurring

a surcharge Total

Cash withdrawals 258,196,539 14.56% 1,515,068,411 85.44% 1,773,264,950

Balance inquiries 0 0 549,647,784 100 549,647,784

Deposits 0 0 566,479,168 100 566,479,168

Fund transfers 0 0 46,078,992 100 46,078,992

Denials 0 0 51,118,549 100 51,118,549

All other transactions 0 0 26,092,976 100 26,092,976

Total transactions 258,196,539 8.57% 2,754,485,880 91.43% 3,012,682,419

Source: GAO analysis.
Appendix II: Selected Results from GAO’s 

Survey on ATM Operator Costs and Operations

Page 43 GAO-13-266 Automated Teller Machines

Table 8: Number and Types of ATM Transactions Reported by Midsize Banks in GAO Survey, Calendar Year 2011

Transaction type

Number incurring

a surcharge 

Percentage 

incurring

a surcharge

Number

not incurring a 

surcharge 

Percentage not 

incurring

a surcharge Total

Cash withdrawals 11,843,819 16.06% 61,923,945 83.94% 73,767,764

Balance inquiries 333,064 0.88 37,523,364 99.12 37,856,428

Deposits 0 0.00 1,954,749 100.00 1,954,749

Fund transfers 13,827 2.63 511,290 97.37 525,117

Denials 37,696 1.54 2,404,319 98.46 2,442,015

All other transactions 48 0.04 113,050 99.96 113,098

Total transactions 12,228,454 10.48% 104,430,717 89.52% 116,659,171

Source: GAO analysis.

Table 9: Number and Types of ATM Transactions Reported by Credit Unions in GAO Survey, Calendar Year 2011

Transaction type

Number incurring

a surcharge 

Percentage 

incurring

a surcharge

Number

not incurring a 

surcharge 

Percentage

not incurring

a surcharge Total

Cash withdrawals 4,450,268 4.53% 93,731,655 95.47% 98,181,923

Balance inquiries 0 0.00 26,204,916 100.00 26,204,916

Deposits 2,891 0.02 17,606,602 99.98 17,609,493

Fund transfers 0 0.00 2,444,887 100.00 2,444,887

Denials 0 0.00 10,381,389 100.00 10,381,389

All other transactions 0 0.00 461,045 100.00 461,045

Total transactions 4,453,159 2.87% 150,830,494 97.13% 155,283,653

Source: GAO analysis.

Table 10: Number and Types of ATM Transactions Reported by Independent ATM Operators in GAO Survey, Calendar Year 

2011

Transaction type

Number incurring

a surcharge 

Percentage 

incurring

a surcharge

Number

not incurring a 

surcharge 

Percentage

not incurring

a surcharge Total

Cash withdrawals 136,536,331 97.09% 4,098,307 2.91% 140,634,638

Balance inquiries 0 0.00 3,017,497 100.00 3,017,497

Deposits 0 0.00 0 0.00 0 

Fund transfers 0 0.00 67,987 100.00 67,987

Denials 0 0.00 2,684,683 100.00 2,684,683

All other transactions 0 0.00 0 0.00 0 

Total transactions 136,536,331 93.26% 9,868,474 6.74% 146,404,805

Source: GAO analysis.
Appendix II: Selected Results from GAO’s 

Survey on ATM Operator Costs and Operations

Page 44 GAO-13-266 Automated Teller Machines

Table 11 shows the average reported per-ATM cost for financial 

institutions for each of the cost categories in our survey questionnaire.3

We are not able to present similar results from the independent operator 

survey since only two out of four firms responded to our questionnaire.4

As shown below, among the data reported by the financial institutions, 

there was a high level of variability across the financial institution types. 

For example, there are several instances in which the per-ATM average 

cost for one financial institution type is much higher or lower in a given 

category than the average of the other financial institution types.5 There 

was also variability in the number of responses for each cost category, 

also shown in table 11.6 Finally, due to the small size and nature of the 

sample, these results are not generalizable to the larger population of 

U.S. financial institutions. The descriptions of the cost categories listed 

below are reproduced verbatim from the survey questionnaire, and all 

data reported are for calendar year 2011.

 

3

We calculated the per-ATM average by summing the costs in a category for all 

institutions of that type (large banks, midsize banks, or credit unions) and then dividing by 

the total number of ATMs represented by those institutions that provided cost data. 

4

As previously discussed, due to the sensitivity and the possibly proprietary nature of the 

information that we collected with the survey, we have aggregated cost information at a 

high level, and we present it in a way that prevents individual organizations from being 

identified. 

5

In instances where we identified a reported cost that appeared to be an outlier, we 

examined the sources reported by the financial institution, and in some cases we followed 

up with representatives from the financial institution to ensure they had reported the 

information correctly and according to the category description in the questionnaire. For 

more on our survey methodology, including quality review of the data, see appendix I.

6

There were two types of nonresponses. First, an institution may not have answered the 

question—providing no cost data for that category. A second type of nonresponse was 

when an institution responded “unable to determine” if they were unable to identify a data 

source for a particular category or were unable to isolate ATM operational costs from 

other related business costs, such as those pertaining to debit cards. 
Appendix II: Selected Results from GAO’s 

Survey on ATM Operator Costs and Operations

Page 45 GAO-13-266 Automated Teller Machines

Table 11: Per-ATM Costs for Financial Institution ATM Operators in GAO Survey, Calendar Year 2011

Cost category and what it includes 

Financial 

institution typea Number of respondentsb Number ofATMs representedc Averagecost per ATM

Rent

• the amount paid for ATM facilities at off-premise 

locations (not in a bank or branch)

• the amount of any revenues shared (partially or 

entirely) with a merchant or other party for ATM 

facilities at that location or locationsd

Large banks 6 out of 10 6,850 $27,173

Midsize banks 6 out of 10 861 4,935

Credit unions 8 out of 10 1,561 4,032

Capitalized ATM hardware and software costs

• costs of the ATM hardware and equipment, both 

purchase and installation, including ATM physical 

security equipment such as boots or bolting 

devices and fraud-prevention software

• costs to upgrade ATM hardware, equipment and 

software (e.g. Americans with Disabilities Act 

(ADA) upgrades, retrofits, etc.)

Large banks 6 out of 10 26,667 28,093

Midsize banks 7 out of 10 2,037 3,059

Credit unions 8 out of 10 2,460 4,564

Noncapitalized ATM hardware and software costs

• costs of the ATM hardware and equipment, both 

purchase and installation, including ATM physical 

security equipment such as boots or bolting 

devices and fraud-prevention software

• costs to upgrade ATM hardware, equipment and 

software (e.g. ADA upgrades, retrofits, etc.)

Large banks 6 out of 10 26,667 515

Midsize banks 7 out of 10 2,037 583

Credit unions 8 out of 10 2,460 2,859

Cash-related costse

• costs related to cash provisioning and 

management for the ATMs, getting the cash to 

the ATM via armored carrier, monitoring the cash 

inventory, and balancing and reconciling cash

Large banks 5 out of 10 20,478 3,495

Midsize banks 7 out of 10 2,037 3,765

Credit unions 8 out of 10 2,460 6,847

Maintenance and repair costse

• costs of first-line maintenance—cleaning, routine 

repairs such as basic troubleshooting, and 

restocking of consumables such as receipt paper

• costs of second-line maintenance—more 

significant repairs that require tools and/or parts 

and labor

Large banks 5 out of 10 20,478 5,444

Midsize banks 8 out of 10 2,066 3,485

Credit unions 8 out of 10 2,460 5,827

Physical security and insurance costs

• insurance policies for cash (not included in 

courier contracts)

• all other insurance costs

• physical security costs, such as contracted 

security, inspections, false alarms, and security 

components and materials (e.g. lighting, 

cameras)

Large banks 4 out of 10 18,211 272

Midsize banks 5 out of 10 1,868 935

Credit unions 6 out of 10 1,935 1,069
Appendix II: Selected Results from GAO’s 

Survey on ATM Operator Costs and Operations

Page 46 GAO-13-266 Automated Teller Machines

Cost category and what it includes 

Financial 

institution typea Number of 

respondentsb Number ofATMs representedc Averagecost per ATM

Infrastructure and processing costse

• telecommunications—costs to install and 

maintain connections to the processor (e.g. local 

area network (LAN), wireless, frame relay, or 

satellite)

• data security—costs incurred in securing the data 

processing and communications infrastructure of 

operations

• processing:

• all fixed and variable cost components of 

equipment/hardware and software associated 

with authorization, clearance, and settlement of 

ATM transactions

• fees associated with transaction processing (e.g., 

switch fees)

• transaction monitoring costs that are a part of 

authorization

• costs associated with interbank settlement and 

account posting

Large banks 4 out of 10 17,467 1,191

Midsize banks 6 out of 10 1,939 3,494

Credit unions 7 out of 10 2,268 7,958

Network fees

• fees charged by card networks that are not 

associated with transaction processing, such as 

membership or license fees

• fees paid for membership in surcharge-free 

networks

Large banks 4 out of 10 18,211 331

Midsize banks 6 out of 10 1,409 340

Credit unions 6 out of 10 1,994 150

Taxes and licenses

• property and sales taxes and state and local 

licenses, both one-time and recurring

Large banks 4 out of 10 18,597 409

Midsize banks 4 out of 10 777 1,188

Credit unions 4 out of 10 1,868 681

Regulatory and compliance costse

• costs of regulatory signage for compliance with 

Electronic Funds Transfer Act and any state 

requirements

• costs of regulatory inspections and examinations

• costs of industry compliance and network audits

• costs of any ADA compliance work not reported 

as part of ATM hardware and software costs 

Large banks 4 out of 10 17,467 282

Midsize banks 7 out of 10 1,438 2,070

Credit unions 6 out of 10 2,185 109

Fraud preventione

• costs related to activities aimed at detecting and 

preventing ATM fraud

• costs related to responding to suspected and 

realized ATM fraud in order to prevent or limit 

losses

• research and development costs incurred in the 

in-house development or improvement of fraud 

prevention techniques

Large banks 3 out of 10 17,789 359

Midsize banks 4 out of 10 1,232 322

Credit unions 3 out of 10 1,407 256
Appendix II: Selected Results from GAO’s 

Survey on ATM Operator Costs and Operations

Page 47 GAO-13-266 Automated Teller Machines

Cost category and what it includes 

Financial 

institution typea Number of 

respondentsb Number ofATMs representedc Averagecost per ATM

Fraud losses (net)

• gross losses incurred, including cash theft and 

ATM robberies, less offsets, such as insurance 

payments, and losses absorbed by other parties, 

such as cardholders

Large banks 3 out of 10 16,330 1,956

Midsize banks 6 out of 10 1,958 505

Credit unions 4 out of 10 378 1,159

Source: GAO analysis.

a

We surveyed a total of 30 financial institutions—the 10 largest banks and 10 largest credit unions (by 

asset size) and 10 randomly selected midsize banks (with assets between $10 million and $50 

million). We are not able to present similar results from the nonbank survey since only two out of four 

firms responded to our questionnaire.

b

There were two types of non-responses. First, an institution may not have answered the question—

providing no cost data for that category. Second, an institution may have responded “unable to 

determine” when they were unable to identify a data source for a particular category, or were unable 

to isolate ATM operational costs from other costs, such as those pertaining to debit cards.

c

For the “Rent” cost category, we only counted off-site ATMs in “number of ATMs represented” since 

we defined rent as the amount paid for ATMs located somewhere other than a financial institution 

facility.

d

Because some revenue sharing arrangements can be based, partially or entirely, on ATM 

transaction levels, rent costs rise as the number of transactions increases.

e

In these categories, respondents were allowed to include the total amount of wages or salaries of inhouse personnel who spent more than half of their time performing tasks related to this cost activity.
Appendix III: Analysis of the Estimated 

Prevalence and Average Amount of ATM fees 

from 2007 to 2012

Page 48 GAO-13-266 Automated Teller Machines

In addition to the analysis of estimated average ATM fees and their 

prevalence for 2012 that we presented in the report, we also conducted 

this analysis for 2007 through 2011. This appendix shows the estimated 

prevalence and average amounts of ATM fees based on four factors 

discussed in the report: type, size, location, and geographic region of the 

financial institution. We analyzed data from Moebs $ervices, Inc. (Moebs), 

a market research firm specializing in financial services data, to assess 

ATM fees charged by financial institution ATM operators. Moebs provided 

data gathered through telephone surveys for each of the years 2007 

through 2012, based on statistically representative samples of financial 

institutions. See appendix I for more detailed information on the 

characteristics of the data. We examined the differences between the 

estimated prevalence and average fees for type and size of financial 

institution, as well as geographic region and type of location of the 

financial institution, separately. We did not conduct a multivariate analysis 

using all of these factors or control for any additional factors in our 

analysis. Dollar amounts for ATM surcharge and foreign fees in this 

appendix are in 2012 dollars, calculated using the Consumer Price Index 

calendar year values. We analyzed the prevalence of charging a 

surcharge and foreign fee, and then we excluded financial institutions that 

did not charge a fee from our calculation of the average fees. We 

computed weighted estimates and 95 percent confidence intervals of the 

percentage of institutions charging surcharge and foreign fees and 

weighted averages of these fees.

We evaluated two types of financial institutions: banks and credit unions. 

Tables 12 through 15 show the variation in estimated prevalence of 

surcharge and foreign fees and estimated average surcharge and foreign 

fees for banks and credit unions from 2007 through 2012.

Appendix III: Analysis of the Estimated 

Prevalence and Average Amount of ATM fees 

from 2007 to 2012

Estimated Prevalence and 

Amounts of Surcharge and 

Foreign Fees by Type of 

Financial Institution
Appendix III: Analysis of the Estimated 

Prevalence and Average Amount of ATM fees 

from 2007 to 2012

Page 49 GAO-13-266 Automated Teller Machines

Table 12: Estimated Percentage of Financial Institutions Charging a Surcharge Fee, by Type of Financial Institution and Year 

(2007-2012)

Bank Credit union

Estimated percentage

95 percent

confidence interval— 

(lower bound, upper bound) Estimated percentage

95 percent

confidence interval— 

(lower bound, upper bound)

2007 92 (88, 95) 81 (75, 86)

2008 88 (81, 93) 76 (67, 83)

2009 93 (87, 96) 77 (68, 84)

2010 96 (93, 98) 88 (84, 92)

2011 95 (90, 98) 96 (94, 98)

2012 97 (95, 98) 95 (93, 96)

Source: GAO analysis of Moebs $ervices data.

Table 13: Estimated Percentage of Financial Institutions Charging a Foreign Fee, by Type of Financial Institution and Year 

(2007-2012)

 Bank Credit union

Estimated percentage

95 percent

confidence interval— 

(lower bound, upper bound) Estimated percentage

95 percent

confidence interval— 

(lower bound, upper bound)

2007 56 (48, 64) 56 (48, 63)

2008 55 (46, 63) 56 (49, 62)

2009 55 (47, 63) 40 (34, 46)

2010 59 (51, 66) 52 (46, 59)

2011 52 (46, 57) 46 (41, 51)

2012 54 (51, 58) 52 (48, 56)

Source: GAO analysis of Moebs $ervices data.
Appendix III: Analysis of the Estimated 

Prevalence and Average Amount of ATM fees 

from 2007 to 2012

Page 50 GAO-13-266 Automated Teller Machines

Table 14: Estimated Average Surcharge Fee, by Type of Financial Institution and Year (2007-2012)

Bank Credit union

Estimated fee

95 percent

confidence interval— 

(lower bound, upper bound) Estimated fee

95 percent

confidence interval— 

(lower bound, upper bound) 

2007 $1.81 (1.73, 1.89) $1.66 (1.57, 1.76)

2008 $1.83 (1.71, 1.94) $1.75 (1.63, 1.87)

2009 $2.01 (1.90, 2.13) $1.84 (1.72, 1.95)

2010 $2.01 (1.93, 2.09) $1.93 (1.84, 2.03)

2011 $2.09 (2.01, 2.16) $1.89 (1.81, 1.98)

2012 $2.16 (2.12, 2.21) $1.99 (1.93, 2.05)

Source: GAO analysis of Moebs $ervices data.

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values.

Table 15: Estimated Average Foreign Fee, by Type of Financial Institution and Year (2007-2012)

Bank Credit union

Estimated fee

95 percent

confidence interval— 

(lower bound, upper bound) Estimated fee

95 percent

confidence interval— 

(lower bound, upper bound) 

2007 $1.45 (1.35, 1.55) $1.27 (1.18, 1.37)

2008 $1.48 (1.34, 1.62) $1.24 (1.17, 1.32)

2009 $1.55 (1.41, 1.70) $1.24 (1.16, 1.32)

2010 $1.49 (1.38, 1.60) $1.34 (1.20, 1.48)

2011 $1.49 (1.42, 1.56) $1.25 (1.19, 1.32)

2012 $1.52 (1.46, 1.59) $1.29 (1.23, 1.36)

Source: GAO analysis of Moebs $ervices data.

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values.

We evaluated three sizes of financial institutions: small financial 

institutions with assets less than $10 million, medium financial institutions 

with assets between $10 million and $999 million, and large financial 

institutions with assets of $1 billion and more. Tables 16 through 19 show 

the estimated prevalence of surcharge and foreign fees and estimated 

average surcharge and foreign fees for small, medium, and large financial 

institutions from 2007 through 2012.

Estimated Prevalence and 

Amounts of Surcharge and 

Foreign Fees by Size of 

Financial Institution
Appendix III: Analysis of the Estimated 

Prevalence and Average Amount of ATM fees 

from 2007 to 2012

Page 51 GAO-13-266 Automated Teller Machines

Table 16: Estimated Percentage of Financial Institutions Charging a Surcharge Fee, by Size of Financial Institution and Year 

(2007-2012)

Small Medium Large

Estimated 

percentage

95 percent confidence 

interval—(lower

bound, upper bound)

Estimated 

percentage

95 percent confidence

interval—(lower

bound, upper bound)

Estimated 

percentage

95 percent confidence 

interval—(lower

bound, upper bound)

2007 84 (77, 88) 92 (90, 94) 87 (80, 92)

2008 76 (67, 83) 91 (85, 95) 87 (80, 92)

2009 80 (71, 86) 93 (91, 95) 98 (94, 99)

2010 92 (87, 95) 94 (92, 96) 92 (86, 96)

2011 96 (92, 98) 95 (89, 98) 98 (95, 99)

2012 95 (93, 97) 97 (95, 98) 97 (95, 99)

Source: GAO analysis of Moebs $ervices data.

Table 17: Estimated Percentage of Financial Institutions Charging a Foreign Fee, by Size of Financial Institution and Year 

(2007-2012)

Small Medium Large

Estimated 

percentage

95 percent confidence 

interval—(lower

bound, upper bound)

Estimated 

percentage

95 percent confidence 

interval—(lower

bound, upper bound)

Estimated 

percentage

95 percent confidence 

interval—(lower

bound, upper bound)

2007 52 (45, 59) 61 (52, 70) 70 (60, 78)

2008 52 (45, 60) 58 (48, 68) 69 (59, 77)

2009 39 (32, 46) 59 (49, 68) 73 (63, 81)

2010 53 (47, 60) 57 (48, 66) 72 (63, 79)

2011 45 (40, 51) 51 (45, 56) 75 (69, 80)

2012 50 (46, 54) 56 (52, 59) 73 (69, 77)

Source: GAO analysis of Moebs $ervices data.
Appendix III: Analysis of the Estimated 

Prevalence and Average Amount of ATM fees 

from 2007 to 2012

Page 52 GAO-13-266 Automated Teller Machines

Table 18: Estimated Average Surcharge Fee, by Size of Financial Institution and Year (2007-2012)

Small Medium Large

Estimated 

fee 

95 percent confidence 

interval—(lower

bound, upper bound) 

Estimated 

fee 

95 percent confidence 

interval—(lower

bound, upper bound) 

Estimated 

fee 

95 percent confidence 

interval—(lower

bound, upper bound) 

2007 $1.72 (1.63, 1.81) $1.76 (1.67, 1.86) $1.98 (1.88, 2.07)

2008 $1.81 (1.68, 1.93) $1.76 (1.63, 1.89) $2.01 (1.88, 2.14)

2009 $1.93 (1.83, 2.04) $1.94 (1.80, 2.09) $2.19 (2.04, 2.35)

2010 $1.97 (1.87, 2.07) $1.97 (1.89, 2.05) $2.17 (2.04, 2.30)

2011 $1.94 (1.85, 2.02) $2.06 (1.98, 2.14) $2.21 (2.11, 2.31)

2012 $2.01 (1.95, 2.07) $2.15 (2.11, 2.20) $2.25 (2.19, 2.31)

Source: GAO analysis of Moebs $ervices data.

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values.

Table 19: Estimated Average Foreign Fee, by Size of Financial Institution and Year (2007-2012)

 

Small Medium Large

Estimated 

fee 

95 percent confidence 

interval—(lower

bound, upper bound) 

Estimated 

fee 

95 percent confidence 

interval—(lower

bound, upper bound) 

Estimated 

fee 

95 percent confidence 

interval—(lower

bound, upper bound) 

2007 $1.32 (1.23, 1.42) $1.37 (1.26, 1.48) $1.73 (1.62, 1.84)

2008 $1.35 (1.25, 1.46) $1.38 (1.22, 1.53) $1.56 (1.46, 1.67)

2009 $1.37 (1.22, 1.52) $1.49 (1.34, 1.65) $1.50 (1.40, 1.59)

2010 $1.34 (1.21, 1.47) $1.52 (1.39, 1.64) $1.57 (1.46, 1.68)

2011 $1.31 (1.24, 1.39) $1.43 (1.36, 1.49) $1.67 (1.55, 1.78)

2012 $1.36 (1.29, 1.43) $1.45 (1.39, 1.51) $1.62 (1.56, 1.68)

Source: GAO analysis of Moebs $ervices data.

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values.

We evaluated four locations of financial institutions: large city, rural, small 

city, and suburban. Tables 20 through 23 show the estimated prevalence 

of surcharge and foreign fees and estimated average surcharge and 

foreign fees for financial institutions located in large city, rural, small city, 

and suburban locations from 2007 through 2012.

Estimated Prevalence and 

Amounts of Surcharge and 

Foreign Fees by Location 

of Financial Institution
Appendix III: Analysis of the Estimated 

Prevalence and Average Amount of ATM fees 

from 2007 to 2012

Page 53 GAO-13-266 Automated Teller Machines

Table 20: Estimated Percentage of Financial Institutions Charging a Surcharge Fee, by Location of Financial Institution and 

Year (2007-2012)

 

Large city Rural Small city Suburban

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

2007 75 (66, 82) 89 (80, 95) 88 (84, 91) 82 (77, 85)

2008 88 (80, 93) 90 (79, 96) 78 (70, 85) 85 (80, 88)

2009 89 (81, 94) 86 (76, 93) 85 (78, 91) 91 (87, 94)

2010 88 (78, 94) 97 (95, 98) 91 (86, 94) 92 (89, 95)

2011 93 (83, 97) 94 (86, 98) 97 (93, 99) 95 (92, 97)

2012 98 (94, 100) 97 (94, 98) 96 (94, 97) 94 (89, 97)

Source: GAO analysis of Moebs $ervices data. 

Table 21: Estimated Percentage of Financial Institutions Charging a Foreign Fee, by Location of Financial Institution and Year 

(2007-2012)

 

Large city Rural Small city Suburban

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

2007 55 (46, 63) 63 (52, 73) 52 (44, 60) 55 (50, 60)

2008 60 (51, 69) 49 (37, 61) 59 (51, 66) 56 (51, 61)

2009 50 (41, 59) 41 (30, 52) 53 (45, 60) 49 (44, 54)

2010 55 (45, 64) 62 (51, 72) 53 (46, 60) 53 (48, 58)

2011 51 (41, 61) 44 (48, 63) 51 (46, 57) 52 (47, 58)

2012 59 (47, 70) 51 (47, 56) 55 (52, 59) 53 (46, 59)

Source: GAO analysis of Moebs $ervices data. 
Appendix III: Analysis of the Estimated 

Prevalence and Average Amount of ATM fees 

from 2007 to 2012

Page 54 GAO-13-266 Automated Teller Machines

Table 22: Estimated Average Surcharge Fee, by Location of Financial Institution and Year (2007-2012)

Large city Rural Small city Suburban

Estimated 

Fee

95 percent 

confidence 

interval— 

(lower bound, 

upper bound)

Estimated 

Fee

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

Fee

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

Fee

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

2007 $1.85 (1.75, 1.96) $1.70 (1.59, 1.81) $1.78 (1.69, 1.88) $1.75 (1.69, 1.80)

2008 $1.71 (1.59, 1.84) $1.73 (1.57, 1.90) $1.85 (1.73, 1.97) $1.81 (1.73, 1.88)

2009 $2.01 (1.88, 2.13) $2.00 (1.84, 2.15) $1.92 (1.79, 2.04) $1.94 (1.87, 2.01)

2010 $2.10 (1.97, 2.23) $1.97 (1.87, 2.08) $1.97 (1.88, 2.06) $2.03 (1.95, 2.11)

2011 $2.07 (1.91, 2.24) $2.02 (1.90, 2.14) $1.99 (1.92, 2.06) $2.08 (1.99, 2.16)

2012 $2.15 (1.98, 2.32) $2.08 (2.01, 2.14) $2.09 (2.04, 2.14) $2.18 (2.06, 2.29)

Source: GAO analysis of Moebs $ervices data.

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values.

Table 23: Estimated Average Foreign Fee, by Location of Financial Institution and Year (2007-2012)

Large city Rural Small city Suburban

Estimated 

Fee

95 percent 

confidence 

interval— 

(lower bound, 

upper bound)

Estimated 

Fee

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

Fee

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

Fee

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

2007 $1.39 (1.27, 1.52) $1.33 (1.21, 1.45) $1.37 (1.26, 1.47) $1.45 (1.35, 1.54)

2008 $1.32 (1.21, 1.42) $1.27 (1.13, 1.40) $1.45 (1.32, 1.58) $1.32 (1.26, 1.38)

2009 $1.45 (1.29, 1.61) $1.46 (1.24, 1.68) $1.44 (1.31, 1.58) $1.36 (1.29, 1.43)

2010 $1.45 (1.29, 1.60) $1.56 (1.40, 1.72) $1.33 (1.21, 1.45) $1.44 (1.35, 1.53)

2011 $1.51 (1.33, 1.69) $1.39 (1.29, 1.48) $1.40 (1.33, 1.46) $1.36 (1.27, 1.45)

2012 $1.36 (1.20, 1.53) $1.40 (1.32, 1.47) $1.44 (1.37, 1.50) $1.42 (1.33, 1.52)

Source: GAO analysis of Moebs $ervices data.

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values.

We evaluated four geographic regions of financial institutions: East, 

Midwest, South, and West. Tables 24 through 27 show the estimated 

prevalence of surcharge and foreign fees and estimated average 

surcharge and foreign fees for financial institutions located in the East, 

Midwest, South, and West from 2007 through 2012.

Estimated Prevalence and 

Amounts of Surcharge and 

Foreign Fees by 

Geographic Region of 

Financial Institution
Appendix III: Analysis of the Estimated 

Prevalence and Average Amount of ATM fees 

from 2007 to 2012

Page 55 GAO-13-266 Automated Teller Machines

Table 24: Estimated Percentage of Financial Institutions Charging a Surcharge Fee, by Region of Financial Institution and 

Year (2007-2012)

 East Midwest South West

Estimated 

percentage

95 percent 

confidence 

interval— 

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

2007 87 (82, 90) 82 (74, 89) 94 (88, 97) 80 (74, 85)

2008 83 (76, 88) 81 (71, 88) 89 (79, 95) 73 (57, 85)

2009 84 (72, 92) 83 (73, 90) 94 (87, 97) 81 (64, 91)

2010 86 (80, 91) 94 (88, 97) 95 (90, 98) 94 (90, 96)

2011 96 (93, 98) 96 (90, 98) 97 (90, 99) 90 (70, 97)

2012 97 (94, 99) 95 (92, 96) 98 (96, 99) 94 (89, 96)

Source: GAO analysis of Moebs $ervices data.

Table 25: Estimated Percentage of Financial Institutions Charging a Foreign Fee, by Region of Financial Institution and Year 

(2007-2012)

East Midwest South West

Estimated 

percentage

95 percent 

confidence 

interval— 

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

percentage

95 percent 

confidence 

interval—

(lower 

bound, upper 

bound)

2007 54 (44, 63) 57 (48, 66) 62 (50, 72) 40 (32, 48)

2008 59 (51, 67) 56 (46, 66) 57 (45, 67) 45 (34, 57)

2009 46 (37, 55) 46 (36, 55) 55 (43, 65) 43 (32, 54)

2010 60 (52, 68) 62 (53, 71) 52 (42, 61) 47 (35, 59)

2011 47 (40, 55) 53 (47, 60) 51 (44, 58) 33 (26, 41)

2012 54 (49, 60) 55 (51, 59) 53 (48, 58) 51 (44, 57)

Source: GAO analysis of Moebs $ervices data.
Appendix III: Analysis of the Estimated 

Prevalence and Average Amount of ATM fees 

from 2007 to 2012

Page 56 GAO-13-266 Automated Teller Machines

Table 26: Estimated Average Surcharge Fee, by Region of Financial Institution and Year (2007-2012)

East Midwest South West

Estimated 

fee 

95 percent 

confidence 

interval— 

(lower bound, 

upper bound)

Estimated 

fee 

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

fee 

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

fee 

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

2007 $1.71 (1.58, 1.83) $1.69 (1.58, 1.80) $1.80 (1.68, 1.92) $1.86 (1.78, 193)

2008 $1.73 (1.58, 1.87) $1.86 (1.75, 1.96) $1.78 (1.60, 1.96) $1.77 (1.62, 1.92)

2009 $1.94 (1.77, 2.11) $1.86 (1.73, 1.98) $2.05 (1.88, 2.22) $1.98 (1.83, 2.12)

2010 $1.90 (1.74, 2.06) $1.86 (1.77, 1.96) $2.08 (1.99, 2.18) $2.14 (1.99, 2.29)

2011 $1.94 (1.80, 2.08) $2.00 (1.92, 2.07) $2.00 (1.90, 2.10) $2.22 (2.08, 2.37)

2012 $2.06 (1.98, 2.13) $2.05 (1.99, 2.11) $2.18 (2.12, 2.25) $2.11 (2.01, 2.20)

Source: GAO analysis of Moebs $ervices data.

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values.

Table 27: Estimated Average Foreign Fee, by Region of Financial Institution and Year (2007-2012)

 East Midwest South West

Estimated 

fee 

95 percent 

confidence 

interval— 

(lower bound, 

upper bound)

Estimated 

fee 

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

fee 

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

Estimated 

fee 

95 percent 

confidence 

interval—

(lower bound, 

upper bound)

2007 $1.27 (1.18, 1.37) $1.40 (1.28, 1.53) $1.37 (1.23, 1.50) $1.41 (1.29, 1.53)

2008 $1.24 (1.16, 1.32) $1.39 (1.25, 1.52) $1.41 (1.23, 1.59) $1.39 (1.20, 1.58)

2009 $1.21 (1.13, 1.28) $1.39 (1.26, 1.52) $1.60 (1.39, 1.82) $1.34 (1.25, 1.43)

2010 $1.39 (1.17, 1.60) $1.32 (1.22, 1.43) $1.58 (1.41, 1.76) $1.44 (1.21, 1.67)

2011 $1.23 (1.15, 1.31) $1.40 (1.31, 1.48) $1.42 (1.34, 1.50) $1.54 (1.43, 1.64)

2012 $1.34 (1.27, 1.42) $1.44 (1.36, 1.52) $1.45 (1.37, 1.53) $1.42 (1.33, 1.52)

Source: GAO analysis of Moebs $ervices data.

Note: Dollar amounts are in 2012 dollars, calculated using the Consumer Price Index calendar year 

values.
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 57 GAO-13-266 Automated Teller Machines

Alicia Puente Cackley, (202) 512-8678 or cackleya@gao.gov

In addition to the contact named above, Paul Schmidt (Assistant 

Director), Jim Ashley, Bethany M. Benitez, Katie Boggs, John Karikari, Jill 

Lacey, Kristeen McLain, Marc Molino, Christine San, Jennifer Schwartz, 

and Andrew Stavisky made significant contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(250640)
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