In March 2011 the Americans with Disabilities Act will requireATMs to offer voice-guided features making them easier to use forpeople who are blind.

A blind person will plug their own headphones into an audiojack. A voice will then prompt the user, sometimes directing themto Braille or other tactile locators that will let them handletheir banking. It's similar to what a sighted person would do tocomplete a telephone transaction.

The ATM Industry Association reports there are about 400,000ATMs in the United States, so any new requirement might soundchallenging. But manufacturers contacted by Credit UnionTimes seem to be taking it in stride.

“The new rules that come into effect in March only require a fewthings that are different from what was there originally in 1991,”Dean Stewart, director of advanced solutions product management atDiebold, said.

“Overall there were certain requirements for accessibilityrelated to height and reach. For example, the highest operablepoint can't be higher than 48 inches off the ground. There has tobe sufficient clearance around the front of the machine for awheelchair.”

“Those things are not new. What is new is a requirement forvoice guidance for the visually impaired and Braille signage toindicate how that voice guidance is activated.”

Response from financial institutions to the new mandates varies,Stewart noted. Whenever a requirement like this is announced aflurry of activity occurs between Diebold and its customers asthose customers work to understand what has changed and evaluatethe equipment they already have.

“There's a lot of that going on right now,” Stewart said.

Can ATMs be retrofitted to meet the new requirements? Stewartexplained the answer depends on the specific machine and perhapsits age. Most major ATM vendors design their machines for a certainamount of upgradeability. It may be possible to add headphone jacksand perhaps more processing power. Older machines may need to bereplaced.

If a credit union needs to upgrade or replace an ATM, are thereother issues to be considered at the same time?

There's always a need for improved security, Stewart responded.There are some industry requirements from the credit card industry,promoted by Visa and MasterCard, to safeguard data and cardholderidentity. There are some basic features available to combat cardskimming and other frauds.

“There's also been a lot of change in the industry based onCheck 21 and deposit automation,” Stewart continued. “It's a goodtime for a credit union that has perhaps been taking envelopedeposits to consider offering check imaging and improve some oftheir operational efficiencies.”

Diebold advises clients to develop a compliance plan, startingwith identifying what level of compliance the financial institutionis at today. Find out from suppliers what options exist for currentmachines. Then get together internally with your chief financialofficer or others to look at what investment is required and whatsteps you can take over time to become compliant. Consider thecoordination that will be needed if you are part of a network suchas Co-Op.

You'll need to understand the timelines involved and what may begrandfathered and what may not. Work with your legal counsel todetermine what you need to implement first. For example, there aresome situations that may grandfather in current ATMs until March15, 2012. You'll need to know if your current ATMs comply with theoriginal 1991 mandates in order to confirm what you'll need to doby what date.

Location may also pose some considerations. The law requiresthat a machine inside a branch and one outside the same branch beconsidered two separate locations. Both must be compliant. But ifthere are two units in the outside wall or inside the branch, onlyone may need to be upgraded.

Joel Antonini, vice president/marketing at Cardtronics, notedATMs have been deployed over many years, and an on-site technicalreview is required to determine if an older machine is outfittedfor voice guidance.

In some cases the ATMs were purchased to handle voice guidance,but it was never implemented and now it's either not working or hasbeen removed or turned off during prior service calls. In othercases an ATM can be upgraded, but a decision must be made if thecost to upgrade that older equipment is worth the investment or ifit is more sensible to replace the ATMs.

“The cost effectiveness of a retrofit depends on the amount ofupgrade required,” Antonini said. “Even if the original equipmentwas configured with some or all of the required components forvoice guidance, if those components were not used they may havebeen damaged or removed over the life of the ATM. It is often thecase that the cheapest and best solution is replacement of theATM.

“In some cases there are no options for retrofitting and ATMsthat were fine for standard ATM services simply need to bereplaced. Often these upgrades are well in advance of when thecredit union would have planned to replace their ATMs in a normalreplenishment cycle.”

Antonini added there is a very short window for credit unions toevaluate their situation, determine the proper plan to achievecompliance, and submit that plan to the Department of Justice byMarch 12, 2011.