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Vision for the future

Facing impending regulatory changes that seem certain to include some kind of a requirement for audio technology at ATMs, some of the country's largest financial institutions are beginning to roll out audio-enabled machines, which are designed to improve access for visually impaired ATM users.

July 30, 2001

Facing impending regulatory changes that seem certain to include some kind of a requirement for audio technology at ATMs, some of the country's largest financial institutions are beginning to roll out audio-enabled machines, which are designed to improve access for visually impaired ATM users.

Nessa Feddis, senior federal counsel for theAmerican Bankers Association, speaking during a late June meeting of theElectronic Funds Transfer Association (EFTA),predicted that the federalAccess Boardwill release its suggested revisions to the Americans with Disabilities Act/Architectural Barriers Act (ADA/ABA) before the end of the summer.

The Access Board published a set ofproposed changesin the Federal Register on Nov. 16, 1999 and collected public comments until May 15, 2000. It also held two informational meetings in October of 2000.

The Board is currently reviewing the comments, more than 2,500 in all, in order to make its final recommendation. The proposed changes were based largely on"Recommendations for a New ADAAG,"an earlier report compiled by the Americans with Disabilities Act Accessibility Guidelines (ADAAG) Review Committee and issued in July of 1996.

While the Access Board proposal addresses a variety of ATM issues, including screen and keyboard modifications, a seemingly innocuous phrase found in Chapter 7 of the document set off a firestorm of debate in the ATM industry. It reads: "Machines shall provide visual and audible instructions for operation."

Among the guidelines included in this section: "Instructions shall be able to be initiated by the user of the machine. After initiation, instructions shall be available for the experienced user to expedite the transaction. Orientation and assistance for unfamiliar users to the physical features of the machine, operational options and details for each function shall be provided. Audible instructions shall be provided through a standard audio mini jack, a telephone handset, a wireless transmission system or another mechanism that is readily available to all customers."

After the Access Board releases its final recommendation, the Department of Justice will seek additional public comment, a process that could take up to another year, before announcing any new requirements. The DOJ is also responsible for enforcing the guidelines.

A little history

According to the first ADA Accessibility Guidelines, in effect since 1992, ATMs were required to be "accessible to and independently usable by blind users." This requirement was "not exactly specific," Feddis said, and was widely interpreted to mean the inclusion of Braille on ATM keypads.

When audio technology became more widely available in the mid-1990s, the visually impaired community began to talk to financial institutions about including some type of audio guidance on their ATMs. There were some limited experiments, such as the Royal Bank of Canada's deployment of a machine with audio lead-through functionality in Ontario, Canada in 1997 – believed to be the first such installation in North America.

However, advocates for the visually impaired were largely dissatisfied with banks' progress toward greater ATM accessibility. Less than 15 percent of blind people can read Braille, according to theNational Federation of the Blind. And Braille on the keypad can't help ATM users decipher screen prompts or error messages.

Curtis Chong, the NFB's director of technology, said the level of frustration among members of the blind community grew as text-to-speech technology became common on PCs. "The idea that you could make a piece of technology talk was something we started to take for granted," Chong told those in attendance at the June EFTA meeting.

The NFB, along with other advocacy groups and blind individuals, filed lawsuits against several financial institutions, including PNC Bank and Mellon Bank, both based in Pittsburgh, and Chevy Chase, Md.-based Chevy Chase Bank.

The Access Board's progress toward a final set of guidelines, combined with the threat of possible litigation, has inspired a handful of financial institutions to begin rolling out ATMs equipped with audio lead-through technology. Others are adopting a "wait and see" attitude, concerned that if current efforts don't meet the standards that are eventually adopted, they will have to make expensive revisions later.

Feddis believes the proactive stance is the better of the two approaches. "I think you're less likely to beome a target if you're doing something," she said.

Fleet Bank: 65 down, 1,355 to go

Boston-basedFleet Bank, with its goal of introducing 1,420 voice-enabled ATMs by the end of 2003, has already deployed 65 audio-enabled ATMs and plans to have 300 by the end of this year. Nandita Bakhshi, the bank's executive vice president of self-service/ATM banking, characterized the rollout as "pretty smooth so far."

Like several of the other large financial institutions that have committed to deploying a large number of voice-enabled machines, including Charlotte, N.C.-based Bank of America and San Francisco-based Wells Fargo, Fleet had already invested in a significant network upgrade because of its interest in offering Web applications and other advanced functionality.

"In our case, we'd already upgraded approximately 50 percent of our other ATMs in order to be able to do other things," Bakhshi said.

When Fleet reaches its target of 1,420 – not quite a third of its fleet of 3,800 machines – Bakhshi said every ATM location will have at least one voice-enabled terminal. "We're trying for a high penetration at our sites," she said.

Learning curve

Because of early trials conducted with representatives from the Boston-based Disability Law Center and the Perkins School for the Blind in Watertown, Mass., Fleet was able to tweak the first machines before they went "live."

For instance, Bakhshi said, the orientation plays on a continuous loop that stops when a user inserts his or her card. After several blind users indicated that they found this a bit too abrupt, Fleet added language that told them the orientation loop would end with the insertion of a card and could be repeated by pressing the "cancel" key.

Other early experiments included a marketing message during the "please wait" portion of the transaction – much like Fleet's standard ATMs – but Bakhshi said this also was somewhat disconcerting for visually impaired users.

"We decided that because this was such a new product, it was not a good time to introduce any message other than the ATM transaction information," she said.

Currently, voice technology is available for cash withdrawals, balance inquiries, cash transfers and deposits at Fleet ATMs. Bakhshi said the bank hopes to add more advanced transactions, including stamp purchases and PIN changes, by 2002.

Fleet garnered plenty of positive publicity – Bakhshi estimated 50 or so TV reports and another 80 print articles – when it introduced its "talking" ATMs in February. Two blind athletes, runner Marla Runyan and skier Rob Walsh, attended the launch at the Perkins School.

 While Bakhshi said that voice-enabled ATMs will never be a mass market product, she does believe they will be used by a wider audience than first envisioned.

 "As we've talked to other individuals in the community, they've told us these will be great ATMs not just for the visually impaired but also for those with learning disabilities who have trouble reading the screens," she said.

 And, she added, elderly ATM users – a fast-growing segment of the population – often have problems with deteriorating eyesight.

 Ultimately, Bakhshi said, voice-enabled ATMs will be a necessary step for banks interested in better serving their customers – whether or not it is mandated by the government.

 "You're not going to get a return on investment for a project like this," she said. "But if you're here to serve your customers, it's become a prerequisite."

 Bank One: Testing, testing

 Chicago-basedBank Onehas deployed 30 voice-enabled ATMs to date – 15 each in Chicago and Columbus, Ohio – with plans to add another 100 by the end of this year.

 Although usage of the machines has been lighter than expected, comments from users and from members of the press have been "almost universally positive," said David Stein, the bank's senior vice president of ATM network management.

 The bank has established a special 800 number to help it gather feedback from users, as well as field their requests for free headsets (like Fleet and other financial institutions offering voice-enabled ATMs, Bank One is giving these away) and provide a list of sites where the machines are located. Users can also register their comments on the bank's Web site.

 "This is a pilot," Stein said. "We've put the technology out there, and now we're measuring it, monitoring it and getting feedback from the user community. As we look at how successful the pilot was – did the technology work, and are people using it? – we'll make the decision on putting more out there."

 Bank One is introducing voice-enabled ATMs now, rather than later, so that it will be better prepared to handle a larger rollout. "There's definitely a learning curve. It's not like you can start from a standstill and ramp up in two weeks," Stein said.

 The bank, which has 5,700 machines, is working closely with its two primary ATM vendors, Diebold and NCR, as well as the MAC Network. The coordination of efforts between all four parties was one of the tasks that proved to be more complicated than expected, Stein said.

 The little guys

 Rob Evans,NCR'smarketing director, agreed that adding more people to the mix can further complicate an already complex task.

 "For the largest banks that run their own switch and have their own programmers, it's going to be easier to get this thing done," Evans said. "But if you rely absolutely on your switch provider for everything, your problems become more significant. We need to recognize that not everybody has the same kind of technical capability as the big guys."

 This is definitely a concern for Austin Roberts, president of the Kilmarnock, Va.-basedBank of Lancaster, a financial institution with $250 million in assets, seven branch locations and six ATMs.

 Noting that his institution outsources nearly every aspect of its ATM program, Roberts said, "We don't have the capacity to handle these challenges by ourselves. We rely on a number of partners. If they aren't there for us, we're dead in the water."

 Roberts questions whether ATM manufacturers can produce the new technology rapidly enough to fulfill the needs of all of their customers. He thinks that those with the largest fleets of machines will be first on the list as orders are filled. "As much as we want (audio technology), if we can't get (our vendors) to deliver it to us, it becomes a moot point," he said.

 "Banks are not obstructionists. One thing they do well is compliance – but they have to be given time to do it," said NCR's Evans, noting that the Access Board has not offered any suggested timetables for implementation of audio technology at ATMs. "They're all going to be vying for the same technical resources to get their applications online."

 The first WAV

 Like Fleet and other financial institutions currently introducing voice guidance at ATMs, Bank One is using WAV, a format for storing sound in files jointly developed by IBM and Microsoft. The de facto standard for sound on PCs ever since it was built into Windows 95, WAV files can be played by nearly all Windows applications that support sound. They can also be modified to run in OS/2, the operating system that drives the overwhelming majority of ATMs today.

Running WAV files at the ATM generally requires a Pentium processor and 64 megabytes of RAM. Adding these features to a typical bank legacy machine can cost $3,000 to $5,000. Also, WAV files require more broadband access than what is found in many of today's ATM networks.

"WAV files ain't small," Evans said. "Most networks aren't built to shove big messages down small pipes.

The text-to-speech technology widely used on the Internet today is cheaper and easier to implement in Windows-based systems – including ATMs – than prerecorded WAV files, but OS/2 is another matter.

"With text-to-speech in a Windows environment, you could simply type your text script and attach it to the HTML screen you're going to display," Evans said. "But because the ATM environment is weird and wonderful and archaic, using text-to-speech technology isn't as simple as taking an engine off the shelf."

Manufacturers like NCR are also relying on WAV because it's a more tested technology, Evans added.

PNC Bank: And now for something completely different

Pittsburgh-basedPNC Bankis piloting an entirely different approach to audio-enabled ATMs. After training several members of its 24-hour call center staff to talk visually impaired users through typical ATM transactions, the bank is recruiting visually impaired PNC customers to participate in a pilot during which they can call for assistance with transactions at 250 machines in the Pittsburgh and Philadelphia areas.

PNC will provide customers who don't have their own cell phones with free phones programmed to dial only two numbers – the bank's call center and 911, said PNC spokesman Patrick McMahon. PNC is promoting the pilot through a statement insert mailed to about 3.1 million customers nationwide that includes a toll-free telephone number that customers can call to register for the pilot or to learn more details.

A joint evaluation will be conducted after the pilot, which will last the earlier of six months or 1,500 ATM transactions. Following the evaluation, a decision will be made on adding more of PNC's 3,200 machines to the program.

"We look forward to the opportunity to evaluate this proposed solution on a broader basis," said Mark J. Murphy, deputy executive director of the Disabilities Law Project and counsel for two visually impaired PNC customers who filed a suit against the bank in June of 1999. "Our goal is to have as many visually impaired people as possible participate in the pilot."

The pilot received preliminary approval from U.S. District Court Judge Donetta Ambrose in January as part of the settlement of the lawsuit.

PNC has already conducted a 30-day preliminary test of the program with several visually impaired users at two ATMs in Pittsburgh. Following that test, some modifications were made to the call center operators' descriptions of transactions, McMahon said.

According to McMahon, the cell phone approach offers several advantages to ATM users that are not possible with standard audio-enabled machines. Perhaps the key benefit, he said, is interaction with a real human being.

"This gives the customer an opportunity to ask questions or to have language clarified if necessary," he said. "Call center representatives can also confirm the details of a transaction. So for example, they might say 'It appears you meant to withdraw $100, but you actually withdrew $150. Would you like to make a deposit, or what would you like to do?'"

Because no major changes to the ATM are necessary, McMahon said a program using cell phones would allow PNC to bring its solution to market very quickly.

"If the pilot goes well, and we get a final sign-off from the two parties (in the suit) and the judge, we'll be able to measure our rollout in terms of months rather than years," he said.

Other financial institutions that have publicly announced plans to audio enable ATMs are Bank of America, which plans to have 2,500 audio-enabled machines within two years; Wells Fargo with plans for 2,000 by the end of this year; Chevy Chase Bank with plans for 500 within three years; New York-based Citibank with plans for 400 by the end of 2002; and Mellon Bank, which has installed 10 audio-enabled machines in Pittsburgh.

On the same team

NCR's Evans said the forthcoming regulatory changes have created "a genuinely cooperative spirit" in the ultra-competitive ATM world.

The important thing, he said, is to concentrate on the basic hurdles – what he calls "the big rocks" – first. Noting that some ATM owners are already beginning to worry about such issues as volume control, he said, "We need to divide the problem up into digestable parts and just get visually impaired folks through the basic ATM transactions first."

Just because a certain set of technologies worked in one specific instance – such as Royal Bank's 1997 deployment of an NCR machine with audio lead-through – doesn't mean it will work in every situation, Evans cautioned.

"This is not a silver bullet waiting for someone to pick it up and load it," he said.

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