Canadian ATMs that are not run by the banks not required to be accessible?
They are installing an ATM machine at my building at work. It's run by one of these "non-bank" service providers. These types of ATMs are called "white label ATMs" because they are independently operated and not run by a bank. We noticed as we were walking by that there was a headset jack on the front of the machine, so I approached the guys installing the unit and had the following discussion:
"Is this new ATM you guys are installing, accessible?"
"What do you mean?" asks the installer
"Can a blind person use it?"
"The unit itself does support it; but because we are not required to in Canada, it hasn't been enabled" says the installer
I walked away in complete shock. Here they have the technology and capability to provide a more universal level of access to their ATMs and they haven't because they aren't required to. This is a good example of why hoping that businesses will "do the right thing on their own" is clearly not working. This same scenario is all too common and is another example of why when need a "Canadians with disabilities act" at the federal level.
Despite being provided with a less-accessible or in most cases completely inaccessible ATM, blind Consumers are now routinely subject to three levels of fees when they use the "white-label" ATMs that are independently operated by private businesses and found in retail stores, shopping malls, etc.: their regular bank account transaction fees plus the network access fee (also known as the INTERAC fee) plus convenience fees charged by the independent operators (and now by some banks). A customer could end up paying total fees of $5.50 or over 27% in fees on a $20 withdrawal!
Where did the "white-label" ATMs come from?
In 1996 the federal Competition Tribunal made an order that opened up the ATM market to independent operators. Prior to this decision, only banks and other deposit taking financial institutions had been allowed to join the Interac Association and operate ATMs.
"White-label" or no name ATMs are mostly owned and operated by private companies, not financial institutions. Any business incorporated and operating in Canada is eligible for membership in the Interac Association, the non-profit corporation that runs the network which allows for the sharing of electronic financial services and the electronic access to bank accounts. The association also sets the convenience fee that is charged to users of "white-label" ATMs.
The Competition Tribunal's mandate is to maintain and encourage fair competition in Canada. Thus the purpose behind the 1996 decision was to increase competition in the ATM market. However, no-where in their documentation, material, mandate or policies does it even remotely hint at the need for accessible ATMs. This lack of inclusion by design will eventually exclude persons with disabilities from options for an accessible ATM.
The growth of "white-label" ATMs is significant. The Canadian Banking Association points out that whereas five years ago, three quarters of ABMs were owned by banks, now less that half are bank-owned. Of the more than 35,000 ATMs in operation in Canada in 2001, over 18,000 of them were "white-label" ATMs compared to over 16,000 operated by financial institutions.
The "white-label" ATMs are increasingly found in locations with high customer traffic such as retail outlets, shopping malls and gas stations. Their growth is a direct result of the financial incentive for merchants to install these machines rather than bank-owned ATMs. The private ATM companies compensate them for installing the "white-label" ATM at a much higher rate than they receive from financial institution ATMs.
As a result, financial institutions are now in direct competition with the private ATMs. Banks are aggressively competing with independent operators to install ATMs in off-premise (retail) locations. In addition, some of the major banks have entered the no name ATM market and are now imposing that 3rd tier of fees, called convenience fees, on non-clients who use their ABMs at retail locations. This recent development has taken place without the knowledge of the consumer. The EKOS survey found that two out of three Canadians are unaware that banks now own no-name ATMs that charge more than the bank's own machines.
Some financial institutions are even charging convenience fees for non-clients who use the financial institution's own ATMs located at branches of that financial institution! Financial institutions have generally charged non-clients who use their ATMs, only the first and second tier fees: the regular bank account transaction fee plus the Interac fee, not the convenience fee.
Who regulates ATMs?
The problem is that no one really does. White-label ABMs are owned and operated by private companies. They are not under federal jurisdiction because they are not financial institutions. As a result, there is a role that provincial governments could and should be playing in terms of regulating the fees and activities of the privately operated "white-label" ATMs.
Doing something about "white-label" ATMs is important because we have grown increasingly dependent upon electronic banking services. According to Ministry of Finance figures, Canada has the highest number of ATMs per capita in the world. In 2001 Canadians conducted 2.2 billion debit card transactions from over 328,000 merchants, ranking Canada first in the world in ATM use. This has happened, not because consumers demanded it, but because financial institutions have gradually withdrawn from providing personal banking services, beginning with the reduction in bank branch hours, followed by branch closures throughout the country.
We as blind consumers need to direct our concerns politically. We should be asking our provincial and federally elected representatives why this significant and growing segment of the financial services sector has been ignored and left unregulated..
Note: a lot of the figures and general material in this blog posting is a direct quote from an article on white label atms by By Sue Lott – Counsel, Public Interest Advocacy Centre