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Vision for the future

by
Ann All, editor
* July 31, 2001

Facing impending regulatory changes that seem certain to include some
kind of a requirement for audio technology at ATMs, some of the country's
largest
financial institutions are beginning to roll out audio-enabled machines,
which are designed to improve access for visually impaired ATM users.

Nessa Feddis, senior federal counsel for the
American Bankers Association,
speaking during a late June meeting of the
Electronic Funds Transfer Association (EFTA),
predicted that the federal
Access Board
will release its suggested revisions to the Americans with Disabilities
Act/Architectural Barriers Act (ADA/ABA) before the end of the summer.

The Access Board published a set of
proposed changes
in the Federal Register on Nov. 16, 1999 and collected public comments
until May 15, 2000. It also held two informational meetings in October of
2000.

The Board is currently reviewing the comments, more than 2,500 in all, in
order to make its final recommendation. The proposed changes were based
largely
on
"Recommendations for a New ADAAG,"
an earlier report compiled by the Americans with Disabilities Act
Accessibility Guidelines (ADAAG) Review Committee and issued in July of
1996.

While the Access Board proposal addresses a variety of ATM issues,
including screen and keyboard modifications, a seemingly innocuous phrase
found in Chapter
7 of the document set off a firestorm of debate in the ATM industry. It
reads: "Machines shall provide visual and audible instructions for
operation."

Among the guidelines included in this section: "Instructions shall be
able to be initiated by the user of the machine. After initiation,
instructions shall
be available for the experienced user to expedite the transaction.
Orientation and assistance for unfamiliar users to the physical features
of the machine,
operational options and details for each function shall be provided.
Audible instructions shall be provided through a standard audio mini
jack, a telephone
handset, a wireless transmission system or another mechanism that is
readily available to all customers."

After the Access Board releases its final recommendation, the Department
of Justice will seek additional public comment, a process that could take
up to
another year, before announcing any new requirements. The DOJ is also
responsible for enforcing the guidelines.

A little history

According to the first ADA Accessibility Guidelines, in effect since
1992, ATMs were required to be "accessible to and independently usable by
blind users."
This requirement was "not exactly specific," Feddis said, and was widely
interpreted to mean the inclusion of Braille on ATM keypads.

Long road to regs:
Sept. 14, 1994
Access Board creates the ADAAG Review Advisory Committee
July 10, 1996
Committee submits its report to the Board
March 11, 1998
Board adopts plan to combine revision of ADAAG with revision of ABA
Accessibility Guidelines, which cover federally funded facilities
March 10, 1999
Board approves a proposed rule
Sept. 3, 1999
Board submits proposed rule to the Office of Management and Budget for
clearance
Nov. 16, 1999  Proposed rule is published in the Federal Register
Jan. 31, 2000
Board holds public hearing on proposed rule in Los Angeles
March 13, 2000
Board holds public hearing on proposed rule in Arlington, Va.
May 15, 2000  Deadline for public comments on the proposed rule; more
than 2,500 comments received
Oct. 3, 2000
Board publishes notice to hold information meetings on ATMs, reach ranges
and captioning on
Oct. 24-25, 2000

When audio technology became more widely available in the mid-1990s, the
visually impaired community began to talk to financial institutions about
including
some type of audio guidance on their ATMs. There were some limited
experiments, such as the Royal Bank of Canada's deployment of a machine
with audio lead-through
functionality in Ontario, Canada in 1997 - believed to be the first such
installation in North America.

However, advocates for the visually impaired were largely dissatisfied
with banks' progress toward greater ATM accessibility. Less than 15
percent of blind
people can read Braille, according to the
National Federation of the Blind.
And Braille on the keypad can't help ATM users decipher screen prompts or
error messages.

Curtis Chong, the NFB's director of technology, said the level of
frustration among members of the blind community grew as text-to-speech
technology became
common on PCs. "The idea that you could make a piece of technology talk
was something we started to take for granted," Chong told those in
attendance at
the June EFTA meeting.

The NFB, along with other advocacy groups and blind individuals, filed
lawsuits against several financial institutions, including PNC Bank and
Mellon Bank,
both based in Pittsburgh, and Chevy Chase, Md.-based Chevy Chase Bank.

The Access Board's progress toward a final set of guidelines, combined
with the threat of possible litigation, has inspired a handful of
financial institutions
to begin rolling out ATMs equipped with audio lead-through technology.
Others are adopting a "wait and see" attitude, concerned that if current
efforts
don't meet the standards that are eventually adopted, they will have to
make expensive revisions later.

Feddis believes the proactive stance is the better of the two approaches.
"I think you're less likely to beome a target if you're doing something,"
she
said.

Fleet Bank: 65 down, 1,355 to go

Boston-based
Fleet Bank,
with its goal of introducing 1,420 voice-enabled ATMs by the end of 2003,
has already deployed 65 audio-enabled ATMs and plans to have 100 by the
end of
this year. Nandita Bakhshi, the bank's senior vice president of
self-service/ATM banking, characterized the rollout as "pretty smooth so
far."

Like several of the other large financial institutions that have
committed to deploying a large number of voice-enabled machines,
including Charlotte, N.C.-based
Bank of America and San Francisco-based Wells Fargo, Fleet had already
invested in a significant network upgrade because of its interest in
offering Web
applications and other advanced functionality.

"In our case, we'd already upgraded approximately 50 percent of our other
ATMs in order to be able to do other things," Bakhshi said.

When Fleet reaches its target of 1,420 - not quite a third of its fleet
of 3,800 machines - Bakhshi said every ATM location will have at least
one voice-enabled
terminal. "We're trying for a high penetration at our sites," she said.

Learning curve

Because of early trials conducted with representatives from the
Boston-based Disability Law Center and the Perkins School for the Blind
in Watertown, Mass.,
Fleet was able to tweak the first machines before they went "live."

For instance, Bakhshi said, the orientation plays on a continuous loop
that stops when a user inserts his or her card. After several blind users
indicated
that they found this a bit too abrupt, Fleet added language that told
them the orientation loop would end with the insertion of a card and
could be repeated
by pressing the "cancel" key.

Other early experiments included a marketing message during the "please
wait" portion of the transaction - much like Fleet's standard ATMs - but
Bakhshi
said this also was somewhat disconcerting for visually impaired users.

"We decided that because this was such a new product, it was not a good
time to introduce any message other than the ATM transaction
 information," she said.

Currently, voice technology is available for cash withdrawals, balance
inquiries, cash transfers and deposits at Fleet ATMs. Bakhshi said the
bank hopes
to add more advanced transactions, including stamp purchases and PIN
changes, by 2002.

Fleet garnered plenty of positive publicity - Bakhshi estimated 50 or so
TV reports and another 80 print articles - when it introduced its
"talking" ATMs
in February. Two blind athletes, runner Marla Runyan and skier Rob Walsh,
attended the launch at the Perkins School.

While Bakhshi said that voice-enabled ATMs will never be a mass market
product, she does believe they will be used by a wider audience than
first envisioned.

"As we've talked to other individuals in the community, they've told us
these will be great ATMs not just for the visually impaired but also for
those with
learning disabilities who have trouble reading the screens," she said.

And, she added, elderly ATM users - a fast-growing segment of the
population - often have problems with deteriorating eyesight.

Ultimately, Bakhshi said, voice-enabled ATMs will be a necessary step for
banks interested in better serving their customers - whether or not it is
mandated
by the government.

"You're not going to get a return on investment for a project like this,"
she said. "But if you're here to serve your customers, it's become a
prerequisite."

Bank One: Testing, testing

Chicago-based
Bank One
has deployed 30 voice-enabled ATMs to date - 15 each in Chicago and
Columbus, Ohio - with plans to add another 100 by the end of this year.

Although usage of the machines has been lighter than expected, comments
from users and from members of the press have been "almost universally
positive,"
said David Stein, the bank's senior vice president of ATM network
management.

The bank has established a special 800 number to help it gather feedback
from users, as well as field their requests for free headsets (like Fleet
and other
financial institutions offering voice-enabled ATMs, Bank One is giving
these away) and provide a list of sites where the machines are located.
Users can
also register their comments on the bank's Web site.

"This is a pilot," Stein said. "We've put the technology out there, and
now we're measuring it, monitoring it and getting feedback from the user
community.
As we look at how successful the pilot was - did the technology work, and
are people using it? - we'll make the decision on putting more out
 there."

Bank One is introducing voice-enabled ATMs now, rather than later, so
that it will be better prepared to handle a larger rollout. "There's
definitely a
learning curve. It's not like you can start from a standstill and ramp up
in two weeks," Stein said.

The bank, which has 5,700 machines, is working closely with its two
primary ATM vendors, Diebold and NCR, as well as the MAC Network. The
coordination of
efforts between all four parties was one of the tasks that proved to be
more complicated than expected, Stein said.

The little guys

Rob Evans,
NCR's
marketing director, agreed that adding more people to the mix can further
complicate an already complex task.

"For the largest banks that run their own switch and have their own
programmers, it's going to be easier to get this thing done," Evans said.
"But if you
rely absolutely on your switch provider for everything, your problems
become more significant. We need to recognize that not everybody has the
same kind
of technical capability as the big guys."

This is definitely a concern for Austin Roberts, president of the
Kilmarnock, Va.-based Bank of Lancaster, a financial institution with
$250 million in
assets, six branch locations and six ATMs.

Noting that his institution outsources nearly every aspect of its ATM
program, Roberts said, "We don't have the capacity to handle these
challenges by ourselves.
We rely on a number of partners. If they aren't there for us, we're dead
in the water."

Roberts questions whether ATM manufacturers can produce the new
technology rapidly enough to fulfill the needs of all of their customers.
He thinks that
those with the largest fleets of machines will be first on the list as
orders are filled. "As much as we want (audio technology), if we can't
get (our
vendors) to deliver it to us, it becomes a moot point," he said.

"Banks are not obstructionists. One thing they do well is compliance -
but they have to be given time to do it," said NCR's Evans, noting that
the Access
Board has not offered any suggested timetables for implementation of
audio technology at ATMs. "They're all going to be vying for the same
technical resources
to get their applications online."

The first WAV

Like Fleet and other financial institutions currently introducing voice
guidance at ATMs, Bank One is using WAV, a format for storing sound in
files jointly
developed by IBM and Microsoft. The de facto standard for sound on PCs
ever since it was built into Windows 95, WAV files can be played by
nearly all Windows
applications that support sound. They can also be modified to run in
OS/2, the operating system that drives the overwhelming majority of ATMs
today.

Running WAV files at the ATM generally requires a Pentium processor and
64 megabytes of RAM. Adding these features to a typical bank legacy
machine can
cost $3,000 to $5,000. Also, WAV files require more broadband access than
what is found in many of today's ATM networks.

"WAV files ain't small," Evans said. "Most networks aren't built to shove
big messages down small pipes.

The text-to-speech technology widely used on the Internet today is
cheaper and easier to implement in Windows-based systems - including
ATMs - than prerecorded
WAV files, but OS/2 is another matter.

"With text-to-speech in a Windows environment, you could simply type your
text script and attach it to the HTML screen you're going to display,"
Evans said.
"But because the ATM environment is weird and wonderful and archaic,
using text-to-speech technology isn't as simple as taking an engine off
the shelf."

Manufacturers like NCR are also relying on WAV because it's a more tested
technology, Evans added.

PNC Bank: And now for something completely different

Pittsburgh-based
PNC Bank
is piloting an entirely different approach to audio-enabled ATMs. After
training several members of its 24-hour call center staff to talk
visually impaired
users through typical ATM transactions, the bank is recruiting visually
impaired PNC customers to participate in a pilot during which they can
call for
assistance with transactions at 250 machines in the Pittsburgh and
Philadelphia areas.

PNC will provide customers who don't have their own cell phones with free
phones programmed to dial only two numbers - the bank's call center and
911, said
PNC spokesman Patrick McMahon. PNC is promoting the pilot through a
statement insert mailed to about 3.1 million customers nationwide that
includes a toll-free
telephone number that customers can call to register for the pilot or to
learn more details.

A joint evaluation will be conducted after the pilot, which will last the
earlier of six months or 1,500 ATM transactions. Following the
evaluation, a decision
will be made on adding more of PNC's 3,200 machines to the program.

"We look forward to the opportunity to evaluate this proposed solution on
a broader basis," said Mark J. Murphy, deputy executive director of the
Disabilities
Law Project and counsel for two visually impaired PNC customers who filed
a suit against the bank in June of 1999. "Our goal is to have as many
visually
impaired people as possible participate in the pilot."

The pilot received preliminary approval from U.S. District Court Judge
Donetta Ambrose in January as part of the settlement of the lawsuit.

PNC has already conducted a 30-day preliminary test of the program with
several visually impaired users at two ATMs in Pittsburgh. Following that
test,
some modifications were made to the call center operators' descriptions
of transactions, McMahon said.

According to McMahon, the cell phone approach offers several advantages
to ATM users that are not possible with standard audio-enabled machines.
Perhaps
the key benefit, he said, is interaction with a real human being.

"This gives the customer an opportunity to ask questions or to have
language clarified if necessary," he said. "Call center representatives
can also confirm
the details of a transaction. So for example, they might say 'It appears
you meant to withdraw $100, but you actually withdrew $150. Would you
like to
make a deposit, or what would you like to do?'"

Because no major changes to the ATM are necessary, McMahon said a program
using cell phones would allow PNC to bring its solution to market very
quickly.

"If the pilot goes well, and we get a final sign-off from the two parties
(in the suit) and the judge, we'll be able to measure our rollout in
terms of
months rather than years," he said.

On the same team

NCR's Evans said the forthcoming regulatory changes have created "a
genuinely cooperative spirit" in the ultra-competitive ATM world.

The important thing, he said, is to concentrate on the basic hurdles -
what he calls "the big rocks" - first. Noting that some ATM owners are
already beginning
to worry about such issues as volume control, he said, "We need to divide
the problem up into digestable parts and just get visually impaired folks
through
the basic ATM transactions first."

Just because a certain set of technologies worked in one specific
instance - such as Royal Bank's 1997 deployment of an NCR machine with
audio lead-through
- doesn't mean it will work in every situation, Evans cautioned.

"This is not a silver bullet waiting for someone to pick it up and load
it," he said.


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