Article

Commentary: Audio ATMs

Kurt Helwig, executive director of the Electronic Funds Transfer Association, says reason and responsibility should prevail when it comes to audio ATMs. The EFTA is hosting a meeting to discuss the issue on June 27 in Arlington, Va.

June 20, 2001

Editor's note: The author, Kurt Helwig, is executive director of theElectronic Funds Transfer Association,an inter-industry, Washington, D.C.- based trade association that promotes the advancement of electronic payment systems and commerce.

Within the coming year, it is a virtual certainty that guidelines will be established that will ultimately require ATM deployers to make some or all terminals "accessible to and independently usable by persons with vision impairments" through voice-enabled technology.

The requirement for voice-enabled ATMs has its basis in the Americans With Disabilities Act (ADA) of 1990, which provides comprehensive civil rights protection to individuals with disabilities. It is also an opportunity for ATM deployers to continue making a significant contribution to the independence of disabled persons, as they have done so in the past with innovations that have made terminals more accessible to both the visually impaired and those confined to wheelchairs

Recognizing responsibility

 Through extensive conversations with EFTA members that deploy ATMs, I have learned that many recognize the need for and their responsibility to provide audio capabilities – or other suitable accommodations – as part of future ATM installations.

 After a reasonable period to allow ATM manufacturers time to integrate voice capabilities into new terminals and other industry participants (e.g., processors, terminal drivers and networks) to develop necessary operational and software support, it is my belief that the visually impaired community will find ATM deployers excellent partners in the effort to reduce barriers to independent use of ATMs by its members.

 I should note here that a number of large ATM deployers have implemented or are currently testing audio ATMs. This is a wonderful development, and these industry leaders are to be applauded for their response to the needs of the visually impaired community. It is also an example of how free market forces work invisibly behind the scenes to expand ATM access to the greatest number of consumers, clearly the goal of almost every deployer.

 The introduction of audio ATMs by major banking companies should not, however, obscure the challenges that a voice-enabled requirement may present to the broader ATM community, particularly smaller deployers and those with more limited resources.

 Compliance guidelines under development by the Architectural and Transportation Barriers Compliance Board (the Board), an independent federal agency, for distribution at yearend will determine the degree of the challenge.

 Grandfathering: Mother of all issues

 The centerpiece of the challenge is the extent to which already installed ATMs will be grandfathered.

 When the ADA was first enacted and regulations implementing it went into effect, many public facilities were grandfathered. The Board clearly recognized the difficulty and inherent inequity of retrospectively applying the guidelines to existing facilities, and appropriately focused its attention on ensuring that new or renovated facilities would meet its specifications for accessibility. The same standard should apply to requirements for audio-capable ATMs.

 Although incorporating audio capabilities in terminals designed for that purpose is not an insignificant effort, current hardware and software technology does make such capabilities feasible. Retrofitting existing ATMs with voice-enabled capabilities, however, is an eminently more challenging undertaking involving issues of software and processor compatibility.

 Some ATMs can be retrofitted, of course, evidenced by those that have already been upgraded. But that ability is not consistent throughout the industry. Newer, high-end terminals are more likely to be upgradeable at a more reasonable cost than older or low-end terminals. Some terminals, including all of those manufactured before 1988, may not be upgradeable at any cost.

 In the tradition of the ADA and consistent with its legislative history, currently installed ATMs should be grandfathered from audio requirements. Any other decision unfairly singles out ATM deployers that have invested in making ATMs more convenient to millions of consumers.

Question of timing

 Accessibility guidelines also should provide a reasonable period after they are issued before compliance becomes mandatory. This period is essential because audio-capable ATMs are not currently widely available.

 Although some ATM manufacturers currently offer terminals with audio capabilities, others have not yet developed marketable products. Time is needed for the marketplace to catch up. Without reasonable lead time, the supply of audio-capable ATMs may not be able to satisfy demand – which would have a chilling effect on future installations.

 A delayed effective date of 36 months would also address the needs of industry participants other than manufacturers – specifically, networks, terminal drivers and processors. These types of organizations must develop support for the audio capabilities that ATM manufacturers develop. Since most of these organizations operate in a multi-vendor environment and each vendor will develop its own unique audio solution, this may represent a formidable task.

 Not the enemy

 ATM deployers recognize their responsibility to use emerging technologies to accommodate persons with disabilities. Today, even without explicit requirements, some ATM deployers are upgrading their terminals with audio capabilities and more are certain to follow. These organizations, with the resources and market power to do so, are helping break down the barriers for visually impaired persons who deserve the opportunity to be independent in every aspect of their lives.

 With guidelines that will effectively lead to more voice-enabled ATMs, ATM service for the visually impaired community will continue to expand and visually impaired persons will benefit.

 Over time, ATMs without voice-enabled capabilities will be replaced with new terminals with integrated audio features. It is prudent to allow the industry to focus on this task, rather than the significantly more difficult and costly exercise of upgrading currently installed ATMs that were never designed to include audio features. It is also prudent to the integrity of the ATM system worldwide to allow the entire industry reasonable time to incorporate and test the new functionality.

 The world of ATMs is vast and interconnected. This is what makes it possible for consumers to use ATMs virtually anywhere in the world to access their funds. It is also what makes the task of a major software and hardware change, such as audio-capable ATMs require, a significant challenge.

 We encourage all of those involved in this industry dialogue to understand that ATM deployers support and will continue to support expanded access by persons with disabilities.

 I don't think that it would be unreasonable to state on behalf of deployers that their goal is to expand ATM convenience to the widest feasible audience. What deployers do not wish to see, however, is overly strict regulation that would ultimately diminish ATM service to all consumers because of issues related to retrofitting or insufficient lead times for compliance.

 ATM deployers should not be treated as the enemy, but as partners in developing reasonable and equitable solutions that consider a multitude of factors.