1NCR Confidential The ADA “Final Rule”  September 15, 2010:  U.S. Department of Justice published final regulations revising its 1991 ADA Title III regulations,

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Presentation transcript:

1NCR Confidential The ADA “Final Rule”  September 15, 2010:  U.S. Department of Justice published final regulations revising its 1991 ADA Title III regulations, including its ADA Standards for Accessible Design (the “1991 Standards”).  The 2010 Standards for Accessible Design (the “2010 Standards”) will become Law March 15,  2010 Standards: Newly mandated communication related auxiliary aids and services.  Exception: fundamental alteration to the public accommodation’s program or undue burden.

2NCR Confidential The ADA “Final Rule”...continued Undue Burden: defined as "significant difficulty or expense." It is evaluated on a case-by-case basis, relative to the business’s overall resources  FIs  seek legal guidance  NCR  work with FI’s Compliance Team Must provide another communication aid or service that still is effective but is less difficult or costly, if one is available.

3NCR Confidential Height and Reach  Forward or side reach (2010):  High  48 inches  Low  15 inches SelfServ ATMs Personas ATMs Will not have to be lowered to meet the 48” max reach range for a side approach until it’s altered! Legal Guidance  alterations trigger 2010 standards?

4NCR Confidential Height and Reach...continued  Operable Parts: “A component of an element used to insert or withdraw objects, or to activate, deactivate, or adjust the element.”  Highest Operable Part on each ATM model is different.  See: Site Preparation Documentation  Touchscreen can be H.O.P.  3 rd Party Applications SelfServ ATMs Personas ATMs Shall be placed within one or more of the reach ranges

5NCR Confidential Privacy  Advisory Note: people who use wheelchairs or have short stature, who cannot effectively block the ATM screen with their bodies, may prefer to use speech output  “blank screen” functionality NCR APTRA Advance NDC NCR APTRA Edge Included in the 3.02 release as a standard feature & will be available as a patch upgrade

6NCR Confidential Speech Output  2010 Standard Requirement: Machines shall be speech enabled NCR APTRA Edge “Text-to-Speech” Multi-Vendor Environment Professional Services NCR APTRA Advance NDC “Text-to-Speech” Nuance RealSpeak Solo TTS

7NCR Confidential Input Controls & Numeric Keys Input Controls Numeric Keys Key surfaces shall be raised above surrounding surfaces Tactilely discernable Keys shall be arranged in a 12-key ascending or descending keypad layout Number 5 key shall be tactilely distinct SelfServ ATMsPersonas ATMs

8NCR Confidential Function Keys  Contrast Visually?  YES!  The “Keyboard” issue SelfServ ATMs Personas ATMs Safe Harbor

9NCR Confidential Display Screen SelfServ ATMs Personas ATMs 40 3/16 Inches above the center of the clear floor space Inch high minimum based on the uppercase letter “I”

10NCR Confidential Braille Instructions Example Voice Guidance Braille Label “"Headphone Jack Below" is nothing more than a label that does not convey the required instructions” ~ Marsha Mazz, U.S. Access Board 2010 Standard Requirement: Braille Instructions for initiating speech mode shall be provided. SelfServ ATMs Personas ATMs

11NCR Confidential Additional Resources  Each ATM operator should get qualified legal advice from their attorney or compliance office, specific to the impact on their ATM installations and operation.  Architectural and Transportation Barriers Compliance Board (ATBCB)   Toll-Free ADA Information Line Call to obtain answers to general and technical questions about the ADA and to order technical assistance materials: (voice) Toll-Free ADA Information Line  Department of Justice   enforcement updates  compliance checklist  American Banker’s Association American Banker’s Association  Nessa Feddis, Senior Counsel