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:
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