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

1NCR ConfidentialNCR 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, 2011.

2010 Standards: Newly mandated communication related auxiliary aids and services. Exception: fundamental alteration to the public accommodation’s

program or undue burden.

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The ADA “Final Rule” ...continued

Undue Burden: defined as "significant difficulty orexpense." 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.

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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?

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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. 3rd Party Applications

SelfServ ATMs

Personas ATMs

Shall be placed within one or more of the reach ranges

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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

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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

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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 ATMs Personas ATMs

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Function Keys

Contrast Visually? YES! The “Keyboard” issue

SelfServ ATMs Personas ATMs

Safe Harbor

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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”

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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

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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) www.access-board.gov Toll-Free ADA Information Line

Call to obtain answers to general and technical questions about the ADA and to order technical assistance materials: 800-514-0301 (voice)

Department of Justice www.usdoj.gov/crt/ada enforcement updates compliance checklist

American Banker’s Association Nessa Feddis, Senior Counsel