ADA Risk Assessment

Has anyone ever completed an ADA Risk Assessment? If so, would you be willing to share?

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Never have. Let me ask the question, why would you develop a risk assessment for a federal law not a banking regulation?

Because there are court intrepretations associated with the law that can result is fines and penalties. Have you seen the fee that one of the major banks just got hit with? http://www.ada.gov/wells_fargo/wf_fact_sheet.htm

The new ADA rules required banks to complete an ADA compliance plan by the effective date of the rule, which I believe was in March 2011. We put together a plan for upgrading our ATMs to the new requirements, as appropriate based on the details of the rule.

We also complete an annual ADA assessment, which reviews accessibility in each of our facilities. If it becomes feasible to implement new accessibility measures, due to technology or what have you, then we would state that those measures will be implemented. Or we will reiterate that some accessibility measures remain too costly or are not feasible to implement (i.e., implementation remains an "undue hardship" for the bank).

I too am wondering about working on a ADA risk assessment. But, mostly, do we need to have an ADA policy? Or does the "plan" cover it? Hum....this whole Wells Fargo situation has me thinking!

We incorporate our assessment into our policy...it's a little funky, because the policy includes the assessment which is updated annually...but we figure since both documents go to the Board for approval, there is no sense in maintaining two documents.

Also, I wouldn't necessarily call it a "risk assessment". It's more of a review of accessibility for our employees and customers against ADA standards.

Thank you for the info. That does sound a little funky but I can totally see why went that direction.

I guess I better get busy on that "review" (I like that word better)!

Does anyone have a checklist that they use that they wouldn't mind sharing?

Rosie - I don't have a checklist, but this PDF from ada.gov is a helpful source on the new 2010 standards.

http://www.ada.gov/regs2010/smallbusiness/smallbusprimer2010.htm

There is also this checklist from ADA's website, but it's dated 1995, so I'd be careful using it.

http://www.ada.gov/racheck.pdf

We haven't yet completed our assessment with the 2010 standards, outside of the ATM upgrades - so we have a ways to go yet ourselves.

Thanks!