Self-Service Kiosk ANPR

To Whom It May Concern:

The American Bankers Association (ABA) appreciates the opportunity to comment on the Architectural and Transportation Barriers Compliance Board’s (Access Board) Advance Notice of Proposed Rulemaking (ANPR) to begin the process of adding self-service transaction machines (SSTMs), including electronic self-service kiosks, to its accessibility guidelines. Kiosks and other types of SSTMs allow users to conduct an expanding range of transactions and functions and are now a common feature in places of public accommodation, government offices, and other facilities. Banks, for example, are deploying electronic self-service kiosks to improve customer service and provide more personalized financial services than traditional automated teller machines (ATMs).

ABA and its members support the Access Board’s goal to improve the accessibility of SSTMs and self-service kiosks given their increasing ubiquity and utility. In promulgating the rule, we urge the Access Board to balance this important goal with practical considerations and technological limitations. Specifically, and in response to the Access Board’s questions, ABA offers the following recommendations:

1. As ATMs are already subject to a separate accessibility standard, ATMs should be excluded from the definition of SSTMs and this rulemaking. In addition, devices that allow customers to engage directly with an institution’s personnel should be excluded since they are not purely self-service devices. Due to their simplicity and privacy concerns, point-of-sale terminals should also be excluded.
2. As is the current rule for ATMs and fare machines, the rule should only require that one SSTM or self-service kiosk machine at each location be accessible.
3. As it supplements its current technical requirements for SSTMs and self-service kiosks, the Access Board should permit functionally equivalent alternatives and apply any new requirements only to machines constructed after the rule’s mandatory effective date.
4. The Access Board should consider the potential impact of the rulemaking on community banks.
5. The ATM and fare machine accessibility standards should not be updated as part of this rulemaking. ATMs and SSTMs are very different devices and requiring institutions to implement two new and different standards during the same time period could be costprohibitive, unnecessarily burdensome, and confusing. 

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