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#1524599 - 03/21/11 05:08 PM Re: ATM - New ADA rules ahou
complofcr Offline
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I have a question regarding the compliance plan (I realize this is a little late). Is there any certain format/outline that it should be in? I just typed mine in a paragraph form in Word.

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Operations Compliance
#1524643 - 03/21/11 05:32 PM Re: ATM - New ADA rules complofcr
Dani York, CRCM Offline
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Doesn't matter what form it is in as long as you cover all the important points. Make sure you have at least inventoried your existing ATMs, determined which ones are upgradable, which ones need to be replaced, the cost of the upgrades and replacements, and your time table for getting it all done by 3/15/12.
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#1524647 - 03/21/11 05:33 PM Re: ATM - New ADA rules Dani York, CRCM
complofcr Offline
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Thanks Dani!!

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#1543340 - 04/29/11 02:52 PM Re: ATM - New ADA rules complofcr
morirse de risa Offline
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Will our regulators (we are OCC) be checking for compliance with these new ADA rules? I'm confused as to who will be regulating this.

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#1543454 - 04/29/11 04:19 PM Re: ATM - New ADA rules morirse de risa
Bob The Banker Offline
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I don't think so, I think it is enforced by the DOJ.

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#1546877 - 05/05/11 07:46 PM Re: ATM - New ADA rules Bob The Banker
Tesla Offline
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If you have a 1991 compliant ATM but you need to add a telephone as a auxilliary communication aid, would that be considered an alteration where you would then have to make the ATM 2010 compliant?
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#1547160 - 05/06/11 01:26 PM Re: ATM - New ADA rules Tesla
Bob The Banker Offline
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Originally Posted By: SkiDoo
If you have a 1991 compliant ATM but you need to add a telephone as a auxilliary communication aid, would that be considered an alteration where you would then have to make the ATM 2010 compliant?

Do not believe so. However, keep in mind it is only structural elements that are given safe harbor and even then readily achievable barrier removal applies.

FYI That is great you are putting a telephone on the ATM, but are you aware that is not required? If possible, you can just have a headphone jack for the customer to plug in typical headphones of theirs.

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#1558662 - 05/31/11 07:46 PM Re: ATM - New ADA rules travelgirl
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Does the compliance plan need to be submitted to the Board for approval?

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#1558857 - 06/01/11 01:07 PM Re: ATM - New ADA rules SomeCommBank
Dani York, CRCM Offline
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If your bank has to invest any money in upgrades, I'm pretty sure your board will want to sign off on it. It can be quite a capital investment/expenditure depending on how many upgrades and the type of upgrades you need to make.
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#1560140 - 06/03/11 01:55 PM Re: ATM - New ADA rules Dani York, CRCM
Daniel Ethridge Offline
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Advisory 707.4 Privacy:

Is a blank screen required or an option? (this was brought up earlier but never answered completely)

Our product folks attended a webinar and this was brought up as potentially required, and they stated that we need to have our own legal team review

Thoughts?

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#1687901 - 04/11/12 04:46 PM Re: ATM - New ADA rules Daniel Ethridge
leo_bsayer Offline
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Sorry for revisiting this old link, but can anyone tell me what the height and reach requirement is referring to - key pad, screen, etc...?

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#1689638 - 04/17/12 07:52 PM Re: ATM - New ADA rules Daniel Ethridge
leo_bsayer Offline
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Still looking for someone who might know what the height and reach requirement is referring to specifically. Thanks!

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#1689691 - 04/17/12 09:08 PM Re: ATM - New ADA rules Daniel Ethridge
Kathleen O. Blanchard Offline

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This has some useful drawings of the requirements and different situations.

And here is the link!

http://www.mcul.org/files/cucorp/744/fil...0FINAL%20HO.pdf
Last edited by Kathleen B; 04/18/12 08:44 AM. Reason: add link
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#1689947 - 04/18/12 04:46 PM Re: ATM - New ADA rules Daniel Ethridge
leo_bsayer Offline
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Thank you very much Kathleen!

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#1690068 - 04/18/12 06:53 PM Re: ATM - New ADA rules Daniel Ethridge
GoGreen Offline
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ATM Compliance
If your institution has not updated its ATMs to meet the new ADA rules, you are behind the power curve. Compliance was mandatory by March 15. We have heard from the ADA that you will not be criticized if the reason for delayed compliance is because your ATM provider could not convert your machines because of scheduling problems, and you have documentation of that fact. The new rules require that all ATMs must be speech enabled to service visually impaired customer. Also, all ATMs must have braille instructions to initiate the voice guidance feature. The only exception is if the cost of the conversion would cause an undue burden or expense to the ATM owner. Also, get out that old measuring stick; the new height and reach requirement is 48 inches for all new ATMs and ATM re-locations.

Send out by TriComply

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#1690316 - 04/19/12 02:03 PM Re: ATM - New ADA rules GoGreen
Bob The Banker Offline
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Originally Posted By: GoGreen
ATM Compliance
If your institution has not updated its ATMs to meet the new ADA rules, you are behind the power curve. Compliance was mandatory by March 15. We have heard from the ADA that you will not be criticized if the reason for delayed compliance is because your ATM provider could not convert your machines because of scheduling problems, and you have documentation of that fact. The new rules require that all ATMs must be speech enabled to service visually impaired customer. Also, all ATMs must have braille instructions to initiate the voice guidance feature. The only exception is if the cost of the conversion would cause an undue burden or expense to the ATM owner. Also, get out that old measuring stick; the new height and reach requirement is 48 inches for all new ATMs and ATM re-locations.

Send out by TriComply

A few thoughts on this message...

"We have heard from the ADA" -- How in the world do you hear from the Americans with Disabilities Act. This is the first I have heard of a law speaking -- especially when the written law provides no such language what-so-ever. They either completely fabricated this statement or incorrectly said they "heard from the ADA"... The Department of Justice could make such a statement, but I have yet to see it, if the DOJ did say this can someone please post a link?

"The new rules require that all ATMs... The only exception is if the cost..." -- Not true, if you have two ATMs in the same location, only one needs to comply. (Keep in mind a drive-up and a walk-up ATM at the same building are considered seperate locations).

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#1690462 - 04/19/12 04:29 PM Re: ATM - New ADA rules Bob The Banker
Pup Offline
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Pedaling along a scenic highwa...
[quote=Bob The Bankerif you have two ATMs in the same location, only one needs to comply. (Keep in mind a drive-up and a walk-up ATM at the same building are considered seperate locations).[/quote]

Bob,

Can you direct me to where this is written? This would save us a good chunk of change at one of our locations. And yes, I realize that we're late, but a plan is in place and we are motoring along. smile

Thank you!

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#1690738 - 04/20/12 11:39 AM Re: ATM - New ADA rules Daniel Ethridge
Bob The Banker Offline
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ADA Guidelines:

ADA CHAPTER 2: SCOPING REQUIREMENTS

220 Automatic Teller Machines and Fare Machines
220.1 General. Where automatic teller machines or self-service fare vending, collection, or adjustment
machines are provided, at least one of each type provided at each location shall comply with 707.
Where bins are provided for envelopes, waste paper, or other purposes, at least one of each type shall
comply with 811.

Advisory 220.1 General. If a bank provides both interior and exterior ATMs, each such
installation is considered a separate location. Accessible ATMs, including those with
speech and those that are within reach of people who use wheelchairs, must provide all the
functions provided to customers at that location at all times. For example, it is unacceptable
for the accessible ATM only to provide cash withdrawals while inaccessible ATMs also sell
theater tickets.
Last edited by Bob The Banker; 04/20/12 11:40 AM.
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#1690854 - 04/20/12 01:48 PM Re: ATM - New ADA rules Daniel Ethridge
Pup Offline
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Pup
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Pedaling along a scenic highwa...
Thank you!!

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#1691144 - 04/20/12 06:02 PM Re: ATM - New ADA rules Pup
Bob The Banker Offline
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Originally Posted By: Pup
Thank you!!

You're welcome!

Pay close attention to the advisory and remember... don't sell theater tickets from your inaccesible ATM but not from your accessible ATM! LOL I get a kick out of that example!
Last edited by Bob The Banker; 04/20/12 06:02 PM.
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#1691162 - 04/20/12 06:28 PM Re: ATM - New ADA rules Daniel Ethridge
Pup Offline
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Pup
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Pedaling along a scenic highwa...
That is good advice. I shall sell no tickets to any type of show from any ATM in my fleet, for sure.

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#1691559 - 04/23/12 04:52 PM Re: ATM - New ADA rules Pup
NancyF Offline
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The related lawsuits have started locally.

http://www.post-gazette.com/stories/loca...r-blind-632652/

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#1692070 - 04/24/12 06:26 PM Re: ATM - New ADA rules Daniel Ethridge
Pup Offline
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Pedaling along a scenic highwa...
The lead time on an ATM is 6-8 weeks. Diebold and NCR are the major providers, and they are using field technicians to do installs just to try to keep up with demand. This was very poorly thought out.

That said, lawsuits such as this one are frivolous and akin to the couple running around seeking out ATM's without their fee notice attached and filing random lawsuits. Banks settle because it's often cost effective to do so, but it's a shame that we can't shut down these types of lawsuits.

We're spending a TON of money on all new ATMs to comply with this demand.

I really need to buy stock in NCR!!

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#1692123 - 04/24/12 07:22 PM Re: ATM - New ADA rules Pup
Bob The Banker Offline
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Originally Posted By: Pup
The lead time on an ATM is 6-8 weeks. Diebold and NCR are the major providers, and they are using field technicians to do installs just to try to keep up with demand. This was very poorly thought out.

That said, lawsuits such as this one are frivolous and akin to the couple running around seeking out ATM's without their fee notice attached and filing random lawsuits. Banks settle because it's often cost effective to do so, but it's a shame that we can't shut down these types of lawsuits.

We're spending a TON of money on all new ATMs to comply with this demand.

I really need to buy stock in NCR!!

Why is this frivolous? The Bank is required by law to provide access and has declined to do so.

This IS poorly thought out, but completely on behalf of the Banks who all wanted to wait until the last minute to put these upgrades in place. Banks were given well what, over 2 years to prepare for this? - those not in compliance now are incompliant because of their failure to take the issue seriously and implement the legally required upgrades.
Last edited by Bob The Banker; 04/24/12 07:25 PM.
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#1692163 - 04/24/12 07:59 PM Re: ATM - New ADA rules Daniel Ethridge
Pup Offline
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Pup
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Pedaling along a scenic highwa...
IMO, they are frivolous because they are brought on primarily by people who are seeking lawsuits rather than by people who are victims or even subjects of the offense (ie-disabled).

The fact that this individual has filed against several local banks is an indication that he simply is looking for a paycheck. Banking regulations aside, it is what is wrong with our justice system. Rather than a lawsuit by an individual, it should be a fine by the regulating agency.

The fee notice thing is easily combatted, and we would win any lawsuits brought on as we have been diligent in documenting, visually, our ATMs with the Fee Notice attached.

Our new machines are being wrapped with the fee notice as part of the design, so it cannot simply be torn off.

Dragging our feet or not, since this came into play, Diebold and NCR have been working non-stop to keep up with demand (and failing), so there was zero possibility that all banks could have been in compliance in time.

Also, the final rules allow for a compliance plan to be in place as we work to get our ATMs replaced.

$2Million is a rough estimate of our cost of replacement. Is that an undue burden? I believe it is if we are expected to do it in quick fashion. We're doing it, as is everyone else, but the majority of the machines are being scrapped ONLY because they don't have the software to talk to the customers. Really? I would be willing to bet that less than 5% of our ATMs will ever have headphones plugged into them after the technician conducts the test at install time.

If I actually ever see someone plug in to use the ATM, I'll be very shocked, and I'll be thankful that we were in the position to help out. But a $2Million invoice to help 10-20 customers over the next few years is a hard one to swallow.

I'm venting, but I'm mostly just upset people who have lost nothing are gaining by taking banks to court...again. That is what I call frivolous.

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