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Some 54,555 ATMs may not be worth upgrading to meet 2010 Americans with Disabilities Act (ADA) compliance requirements because the machines don't meet their financial institutions' minimum standards for profitability, Leon Majors, president of the Payment Systems Practice of Phoenix Marketing International, said during a Webinar on Wednesday that was sponsored by Diebold Inc. and hosted by ATMmarketplace.com.

Majors said 34,855 ATMs operated by independent ATM deployers (IADs) and 19,700 ATMs operated by banks and credit unions either will have to be upgraded, replaced or removed because they do not have a sufficiently high monthly transaction volume to make the machines profitable to their owners.

A bank-owned ATM must have a volume of around 1,200 transactions per month to reach the machine's financial breakeven point. An IAD-owned machine must have 100 to 200 monthly transactions to meet the machine's financial breakeven point based on 2010 data, Majors said.

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The U.S. Department of Justice requires that by March 15, 2012, ATMs meet physical access and communication standards. At that point the 1991 ADA guidelines are no longer in effect, said Dean Stewart, Diebold's senior director of advanced solutions product management.

The new ADA regulations became law on March 15, 2011, when the new rules were published in the Federal Register, but the Department of Justice gave ATM deployers one year to implement the new guidelines.

According to the federal government, the top of an ATM cannot exceed 48 inches in height or be lower than 15 inches off the ground. The ATM owner must provide an unobstructed accessible route to the ATM. The ground space near the ATM must be 30 inches by 48 inches to allow for a person to maneuver in a wheelchair. If the ATM is located in an alcove the forward approach must be 36 inches wide by 24 inches. A parallel approach alcove must be 60 inches wide by 15 inches minimum.

The Americans with Disabilities Act communications elements require that the ATM must be speech-enabled to accommodate the visually impaired and individuals who have mobility issues and cannot effectively block the screen with their bodies for privacy.
 
At least one tactile bump must appear on each discernible input control and numeric key in a 12-key ascending or descending telephone keypad. Function keys must contrast visually from the background surfaces. The following function keys must have tactile symbols: "Enter" or "Proceed" keys must have a raised circle; "Clear" or "Correct" key must have a raised left arrow. The "Cancel" key must have a raised X; and the "Add Value" key must have a raised plus sign and the "Decrease Value" key must have a raised minus sign.

The ATM's display screen must be visible from a point located 40 inches above the center of the clear floor space and the screen's characters must be in a sans serif font. Characters must be a minimum of 3/16 of an inch high. Specific Braille instructions for initiating the speech through the headphone jack must be fixed on the ATM near the jack.

The major changes that were not included in the 1991 ADA guidelines concern privacy, Stewart said. Once an ATM user plugs in a headphone, the machine will ask the user whether he or she wants the screen to go blank. This is known as screen blanking. This process prevents someone standing in line behind the user from "shoulder surfing." The user then would continue the transaction through voice instructions, Stewart said.

The 2010 guidelines also require the ATM owner to offer instructions in Braille on the headphone jack, he added. The new standards also restrict protrusion limit, such as a writing desk at the ATM. The desk cannot extend more than four inches from the ATM, Stewart said.

Depending on the company, an owner may decide to upgrade the machine, replace it or risk not doing anything in the hope that the ATMs don't catch the attention of the U.S. Department of Justice (DOJ) or private citizens who could file lawsuits against the owner. If the company is planning to install ATMs in a planned building, they must meet the 2010 ADA guidelines. If the ATMs do not meet the 2010 guidelines, a building inspector may not approve the building construction plans.

Stewart encouraged ATM deployers to develop a five-step plan to meet ADA guidelines. This includes taking an inventory of the ATM network to determine if the machines are compliant with the 1991 ADA guidelines, comparing the ATMs' 1991 standards with the 2010 standards, consulting an ATM vendor, establishing a budget and periodically reviewing the plan.

Majors said there are 225,000 FI-owned ATMs, and 97,000 ATMs owned by banks and credit unions are in full compliance with ADA requirements. One hundred and fifty thousand financial institution-owned ATMs meet the audio requirement, but 75,000 FI-owned ATMs don't have audio jacks based on 2010 data, he said.

There are 215,000 IAD-owned ATMs, and 65,900 IAD-owned ATMs are in ADA full compliance, and 140,676-IAD-owned ATMs have met the voice requirement. But 74,324 IAD-owned ATMs do not have audio jacks based on 2010 data, Majors said.

He added that 10,000 to 15,000 IAD-owned ATMs could be removed in addition to the normal replacement cycle of 30,000 machines annually. As for financial institutions, 10,000 ATMs could be removed in addition to the normal ATM replacement cycle, which is above 20,000 machines annually.

So what happens if a financial institution or IAD-owned ATM does not meet the ADA requirements by the March 15, 2012, deadline?

"There's no ADA police," Stewart said. "The machines will continue to operate. No one is going to put black and yellow tape over the machine." As mentioned earlier, the owner may be subject to consumer lawsuits, he said.

Majors said, however, there is a strong financial incentive for financial institutions and IADs to meet the ADA guidelines. "There are 50 million to 65 million people, or 16 percent to 22 percent of the nation's population, who have declared they are visually disabled, hearing impaired or unable to easily move around," he said. "It would be good if [the number of] people with physical impairments would get smaller, but it looks as though the numbers will get larger."