36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

Comment. Comments from the banking industry opposed the specific criteria proposed for ATMs in favor of a more flexible performance standard. Conversely, many comments from persons with vision impairments supported the proposed specifications or urged the Board to make them more stringent.

Response. The original ADAAG relied on a performance criterion in specifying access to ATMs for people with vision impairments: "instructions and all information for use shall be made accessible to and independently usable by persons with vision impairments" (4.34.5). Based on the level of access provided at ATMs under the original ADAAG, it is the Board’s belief, consistent with the ADAAG Review Advisory Committee’s recommendations, that a descriptive set of technical criteria is essential to ensure that ATMs are adequately accessible to, and usable by, persons with vision impairments. The Board has taken into consideration concerns raised by industry concerning various specifications, as well as information on improved technological solutions, in finalizing these criteria. A number of revisions have been made to the ATM requirements which are detailed below.