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Lawsuits over Non-ADA-Compliant ATMs Persist
Monday, December 29, 2014 6:15 AM

Required ATM Features for Visually Impaired Members Still Missing

By Roger Nettie

When credit unions are notified—or worse, sued—because their ATMs aren’t properly accessible to visually impaired people, the credit unions usually have one of two reasons for the non-compliant machines:

  • We’ve upgraded our ATMs, and we thought they were fully compliant with Americans with Disabilities Act (ADA) requirements now.
  • We’re in the process of upgrading our ATMs to be ADA compliant, and we’re following a written plan we had in place by the March 15, 2012, deadline.

This well-intentioned but incorrect reasoning is partly why class-action lawsuits related to the ADA’s accessibility requirements persist in our industry, more than two years after the mandatory implementation date.

A mistake some credit unions have made is assuming that a new or upgraded machine was ADA compliant because they believe the manufacturer and/or installer said it was. Even if the hardware has all the necessary capabilities, you still need to confirm that the accessibility features are enabled and stay in working order.

If you’re still in the process of converting your ATMs for ADA compliance, the fact that you have a written plan to complete the process won’t protect you from lawsuits in most cases. It’s time to make completing the conversions a higher priority.

Take These Steps toward ADA-Compliant ATMs

  • Include ADA compliance in routine ATM inspections at the same time you’re checking them for security concerns, foreign devices such as skimmers, fee disclosers, and funds availability. Machines should be physically inspected at least once per month. The inspector should always bring headphones or ear buds to check that the audio jack is working.
  • Use a checklist to document your inspection so you don’t miss any key functions that a visually impaired user might need. Consider taking a photo to make the documentation even stronger.
  • Look for these common ADA compliance issues:
    • The voice activation feature doesn’t work.
    • Lack of privacy features. For example, the screen should go blank when the user activates the speech function, so nobody can look over the user’s shoulder and see private information.
    • The headphone jack is broken or isn’t enabled.
    • No volume control.
    • No repeat/interrupt function.
    • No sticker with Braille instructions.
    • Function keys don’t have raised symbols.


Make sure your visually impaired members can safely and easily use your ATMs. It’s not only good service; it protects you from potentially expensive and embarrassing litigation.

For More Information
CUNA Mutual Group’s Credit Union Protection customers have access to Protection Resource Center resources, including:

Checklist: ATM Inspections
Webinar: ATM Risks – What You Don’t Know Can Hurt You
RISK Alert: ATMs and the Americans with Disabilities Act (ADA) GET IN COMPLIANCE NOW; ATMs and ADA. Upgrade? Unplugged? Or, Understand Your Assumed Risk?

© CUNA Mutual Group 2014, All Rights Reserved.


Roger Nettie is a senior risk management consultant for CUNA Mutual Group. Reach him at

Insurance products offered to credit unions are underwritten by CUMIS Insurance Society, Inc., a member of the CUNA Mutual Group. CUNA Mutual Group does not provide any warranties or guarantees with respect to the performance of services by any vendor, and is not liable for any products or services purchased from any vendor by any credit union. Each credit union is ultimately responsible for determining the products and services that it may require, selecting the vendor that best meets the credit union’s needs and contracting directly with that vendor.