That was the price our IT Department relayed to us. They received an estimate from our ATM vendor. But yes, our ATMs are quite old. I do not know if they are currently compliant with the 1991 standards, but they are definitely not compliant with the 2010 rules.

I would ask for a detailed report to see if they are unnecessarily upgrading structural elements that have a safe harbor, because $15,000+ per ATM is an exuberant amount. You would have to prove this "estimate" to hold water in order to claim undue burden.

Most of the changes are software issues, software is a reletively cheap upgrade.

Trying to get our arms around this one. Our ATMs are all old as dirt.

What we're running into is that the processors aren't up to the task of running the OS version required to support speech, and Diebold is telling us they aren't upgradeable (1074I, 1064I, and 1064IX machines). The speech requirement is the one that's killing us. We're looking at buying a bunch of new hardware just so they can talk to you.

Most of our machines are free standing (hospital and university lobbies). Unless they're exempted from all this, we'll probably just pull these machines altogether rather than purchase new ones.

Hi!
does anyone know what the rules are for drive up ATMs? I know we do not have to comply with certain items but not sure what ones we must do. Does anyone have a punch list of changes?

Yikes focus!

Our institution has the same problem as focus, unfortunately our ATMs are not freestanding. We use Diebold as well and have the same model of ATM. Hence the huge expense in upgrades.

We were notified that Diebold is ending their support of the 1072ix & 1074ix ATMs in the next few years, so we are not upgrading. Fortunately, we've already budgeted for replacements.

The majority of our locations have one walk-up ATM and one drive-up ATM. If the walk-up is fully ADA compliant, do we need to upgrade the drive-up to be fully compliant (ie: speach output)?

According to the ABA analysis, if we have two ATMs at one location, only one needs to be accessible. However, this statement is directly after a paragraph speaking about physical access. Are they saying if the walk-up is fully compliant the drive-up does not have to be? Or are they simply speaking in the aspect of physical access, not speach and auxilary capabilities?

Answered my own questions. But it is tricky...

If you have two or more ATMs in one location, then only one needs to be fully compliant. HOWEVER, if a branch has interior and exterior ATMs, they are considered seperate locations. i.e. if you have a drive-up only ATM and a walk-up ATM in your vestibule, they are considered seperate locations and both are to comply.

So, to summarize:
- Some exceptions apply to drive-up machines; generally in re: to structural elements in a common-sense sort of way.
- Speech is considered auxiliary - there are no exceptions for auxiliary functions.
- This is on a per location basis, meaning in an ATM farm only 1 must be fully compliant. (Important note, external/internal are considered seperate locations.) Does this include the speech requirement?
- We need to have a gameplan figured out by March 2011. We need to be functionally compliant by March 2012.

Question: Free-standing machines: different ballgame altogether? Do auxiliary functions (speech) apply? Or is the structural stuff the only exception/difference we're talking about?

Since this would apply to ADA rules and ATMs i thought i would ask on this string. Our Bank's ATMs currently have signs that disclose our OD fees and practices on the ATM. With the new ADA law it looks like this would need to be either in brail or incorporated into the screens for speech output. We already have the foreign cardholder atm withdrawal fee as and ATM screen, but not the OD dosclosure. What is everyone else doing about this?

I have another question to add. Our Diebold rep passed on an opinion expressed by another customer that ATMs on a military based would not be covered. Has anyone else had that come up?

Hmmm.. So no one with a disability is allowed on military bases??

Here is what I have determined for Drive up ATMs.
And yes I beleive it is March 2012

1 Tactile symbols (should already have this)
2 Speech output for
a) Instructions
b) Transaction Prompts
c) Input verification
d) Error Messages
e) Key items on the receipt
3 Speech output options are either a Handset or an industry standard headphone jack (I would think a handset would be too easy for vandals to rip-off)
4 Volume Control

I have been researching this all morning, is there some place that I could find the final rule summarized only for ATM requirements. I have read a lot about the other rules but seem to find what I'm looking for! Thanks.

I called and spoke with the ADA's helpline and they relayed the following information to me when I expressed that updating 60+ ATMs would be an undue burden:

If the ATMs met the 1991 standards by March 15, 2012, we would not be required to act.

If we were upgrading or altering an ATM between September 15, 2010 and March 15, 2010, we could choose to either follow the 1991 standards or the 2010 standards.

If the ATM was upgraded or updated on March 15, 2010, the ATM is required to conform with the 2010 standards.

Also, a compliance plan must be in place by March 15, 2011 for all ATMs that currently do not comply with 1991 standards and for any ATMs that we plan on upgrading or updating between now and March 15, 2012.

If I were you, I would get this in writing.

Also, if you have an undue burden, you have to prove it. Not just say 60 ATMs is a lot of work.

I am being told that the new ADA requirements include a Privacy issue. We need to do a software upgrade so that the screen goes blank when the customer plugs into the jack. This is because someone in a wheelchair cannot block the screen for privacy.

Is this actually required?
Is it a auxillary aide that must be done by the deadline or is it a structural item that has safe harbor?

707.4 Privacy. Automatic teller machines shall provide the opportunity for the same degree of privacy of input and output available to all individuals.

Advisory 707.4 Privacy. In addition to people who are blind or visually impaired, people with limited reach who use wheelchairs or have short stature, who cannot effectively block the ATM screen with their bodies, may prefer to use speech output. Speech output users can benefit from an option to render the visible screen blank, thereby affording them greater personal security and privacy.

So, do free standing ATM's have different mandates or do the same rules apply?

Sorry to repeat someone else's question, but does anyone have anything that summarizes this new rule along with mandatory compliance dates? Also, does anyone have anything in writing confirming what Seastar heard verbally from the ADA?

[emphasis added]

I have not been able to find anything within the final regulation as published in the Federal Register that addresses the need to have a compliance plan in place by March 2011. I know that was included in the ABA Summary Analysis, but in detailed reading of the final rule it doesn't seem clear that there is an opportunity for banks to have a final compliance date of March 2012 or the plan in place by March 2011. Has anyone been able to confirm this information with reference to the final rule itself? Thanks!

This is a helpful summary from the ABA:

http://www.aba.com/aba/documents/news/ADAAnalysisAug2010.pdf

I would not rely on the words of the ADA Helpline to consider yourself in compliance. Many banks were burned by doing the same thing with the HMDA Helpline.

I did find that the ABA posted a revised version of their analysis after their December 7th webinar. The revised version does better clarify the mandatory compliance dates.

http://www.aba.com/NR/rdonlyres/CE8DC4FB-FBD4-4312-B499-9AE051507C8A/69980/SA_ADA_ONeill2010dec.pdf

[Note: Available only to ABA members with "members only" access codes and passwords.]