The U.S. Access Board is soliciting feedback on a plan to develop accessibility standards for SSTMs based on existing accessibility standards, including the existing standards for ATMs and fare machines. In the letter, ABA said it and its members support the board’s goal to improve the accessibility of SSTMs and self-service kiosks, but that goal should be balanced with practical considerations and technological limitations.

In response to specific questions put forward by the Access Board, ABA recommended that the agency exclude ATMs, devices that allow customers to engage directly with an institution’s personnel, and point-of-sale terminal devices from the definition of SSTMs. ATMs are already subject to a separate accessibility standards, so the association urged the board not to update the ATM and fare machine accessibility standards as part of the rulemaking. It also urged the board to only require one SSTM or self-service kiosk machine at each location to be accessible.

For the technical requirements of the rule, ABA recommended the board permit functionally equivalent alternatives to the specific technical requirements and apply any new requirements only to SSTMs and self-service kiosk machines constructed after the rule’s mandatory effective date. ABA further suggested the board consider the potential economic implications for community banks.