Banks are building
"There is a lot of debate about how the ADA [Americans with Disabilities Act] does or does not apply" to digital properties, said Tim Springer, founder and CEO of Level Access, which helps companies ensure their digital properties are accessible and legally compliant. "Most banks will say there is enough legal risk associated with this that it is prudent to assume the ADA applies to some degree."
The Americans with Disabilities Act, enacted in 1990, prohibits discrimination in places of public accommodation — including banks — under Title III. In March of 2022, the Department of Justice published guidance emphasizing that covered entities must ensure their online presence is accessible to people with disabilities in line with the ADA's requirements. However, the ADA does not contain technical requirements for digital access, nor did the guidance spell out how to achieve this, beyond pointing to existing technical standards such as the Web Content Accessibility Guidelines, or WCAG.
Beyond the legal and moral obligations entwined with digital accessibility, there is a business case to be made for helping customers smoothly navigate their bank websites and mobile apps, which can reduce the need to travel to branches and ATMs.
"We have noticed that this demographic is loyal and they will tell their friends and their families about their experiences," said Sabrena Foxx, senior director of the accessibility program at Ally Financial in Detroit.
Thomas Foley, executive director of the National Disability Institute, points to figures from the Federal Deposit Insurance Corp.'s 2021 survey of unbanked and underbanked households. The unbanked rate for working-age households with a disability is 14.8%, compared to 3.7% for households without a disability.
"Sometimes people with disabilities are seen as a group to be served rather than part of a consumer base you want to attract as new customers," said Foley. "Having a really good digital experience is one of the ways to do that."
U.S. Bank and Regions revamped their apps with accessibility in mind; JPMorgan Chase built a branch for customers who are deaf. Such efforts can help banks appeal to more customers in existing markets.
One issue that financial institutions contend with is catering to diverse conditions and abilities.
"This is a very big group that is not homogenous in any way," said Springer.
Mahalo Technologies, a credit union services organization, revamped its Mahalo Banking online and mobile platform in February. Its digital banking technology integrates functionality for neurodiverse conditions including dyslexia, autism, attention-deficit disorder, epilepsy and more. These include a "left hand" mode, which switches the layout of the credit union's mobile app; font and color options for people with dyslexia; multiple palettes for different forms of colorblindness; light and dark modes and the ability to disable animations for people affected by epilepsy. The product integrates directly into several cores used by credit unions, including Corelation KeyStone and Jack Henry's Symitar.
Mahalo worked with Park View Federal Credit Union, its beta client for this version of its digital banking software, to find the right balance delivering information on screen that is user-friendly and not overly cluttered. Park View, which is based in Harrisonburg, Virginia, was also the first credit union to go live with the software. Now, Mahalo has 33 credit union clients.
"When we started designing this, we didn't want to be in a bubble," said Jim Stickley, CEO of Mahalo.
Tanya Holland, director of digital operations at the $350 million-asset credit union, said feedback has been positive.
"Our members are able to do more self-service than they ever could before," she said.
In March, TD Bank Group, which has about $1.4 trillion in assets in U.S. dollars, started
People who already use assistive technologies may prefer sticking with what they have than using features bolted to a bank's website.
"[Companies] need to be careful that their technologies don't override or duplicate the technology that people are already using and accustomed to, whether it's a screen reader, enlargement, colors or font sizes," said Marsha Schwanke, a specialist at the Southeast ADA Center, which provides technical guidance on the ADA.
Stickley said Mahalo hired third parties to review its entire solution to ensure it "not only did everything we thought we needed to do but it was also playing nice with all the other stuff out there," he said. TD also says its preferences will coexist with other assistive technologies, such as standalone screen magnification software.
These customizable features may be especially helpful for those with newly acquired or undisclosed conditions, or simply for anyone experiencing the onset of vision, motor or hearing loss.
"My parents would not identify as having a disability, but 100% they will change the font size on their phones," said Springer.
"Disability impacts all of us, either temporarily or permanently," said Schwanke.
Some banks turn to accessibility compliance partners to bake in best practices from the start.
For instance, seven years ago Ally Financial in Detroit partnered with Deque Systems, which helps companies with web accessibility compliance, to bolster its accessibility program. Ally, which has $196 billion of assets, aligns with WCAG 2.1 AA standards. Level AA is the level most organizations strive to meet, according to the World Wide Web Consortium. The 2.1 version of WCAG guidelines is the most recent one, although the 2.2 version will be finalized in the third quarter of 2023.
"But we know there is so much more you can do besides meeting those baseline requirements," said Foxx. "We have instituted an inclusive design team that is thinking beyond what is required from a legal aspect."
For example, Ally tests its web designs with users with disabilities before they go live.
"That isn't a requirement, but having that voice of customers gives us a better view," said Foxx.
Because financial management is so critical, banks should be reviewing the accessibility of their user experience with people because "you can have 100% in passing a test and still have a fail for a product as far as true usability," said Schwanke. "It will always cost more time, money and stress trying to retrofit something."
Another Ally development is a setting that lets users change the background colors on their desktops or mobile devices to a dark palette that Foxx says will offer a better visual experience than users changing the color schemes in their operating systems. For now, the settings are available for Ally Invest users, but the company is building the same functionality for other divisions of Ally.
"We found this doesn't only help users with low vision, but it also helps users with a cognitive disability," said Foxx. "Reducing that eye strain reduces the cognitive load and helps that person stay more focused."
Now that its accessibility program is up and running, Ally turns to Deque for more niche questions and to understand trends in the industry.
Smaller banks may not have the resources or sway that larger banks do in this arena.
Jon Avila, chief accessibility officer at Level Access, points out that many banks procure third-party components to enable digital banking.
"The bigger banks tend to be more compliant than smaller banks, all things being equal, because they own more of the technology stack," said Springer. "They also tend to have more leverage with their suppliers."
Smaller banks should focus on what they can control, Springer said, as well as solicit feedback from people with disabilities, prioritize features based on their impact on the user experience and avoid introducing inaccessible features.
There are still gaps among larger banks.
In its semi-annual evaluation in May of online banking at 18 large U.S. banks, Keynova Group found that 89% offer closed captioning for video content, 78% support screen readers to open a new deposit account and 39% provide audio descriptions for embedded videos.
In 2021, an
Schwanke points out there are plenty of subtle potential gaps in web accessibility, such as displaying a QR code but not accompanying it with text instructions such as "scan to register."
"Accessibility is like a journey. It's not checking off a box," said Schwanke. "It has to be a continuum because the technology is not static."
