About Us | Contact Us
View Cart

Beware the Ides of March, Maybe?

By Dan Hadaway | Wednesday, March 14, 2012 - Leave a Comment

If you’re still scrambling to comply with the 2010 American with Disabilities Act update requiring ATMs to be handicap accessible, you are not alone.  A Wall Street Journal article by Robin Sidel articulates that many banks are simply at the mercy of their ATM vendors and are not going to be ready by the March 15th deadline.

This whole issue helps illustrate one reason an annual update to your IT Strategy is a good idea.

Though the primary cause of banks not being ready is the order backlogs, banks that actively work a strategy document can show a paper trail demonstrating why it’s March 15th, 2012, and they are still not compliant.

Way back a year ago, those banks who are indeed actively managing a documented strategy inserted into their 2011 IT Strategy an update to their ATMs.  The tactical plan included documentation that they would investigate cost and priority issues.  Then, throughout 2001, reports on progress showed that the advent of wireless banking, the June 2011 Supplement to the October 2005 Authentication Guidance, and budgetary issues made the already difficult task of upgrading our ATMs more difficult.  From a risk perspective, these banks could demonstrate that though they were working with their vendors, there were bigger fish to fry.

Some banks are considering the overhaul of their ATMs to be “an undue burden,” which the updated ADA would allow as an excuse for non-compliance.  For example, BB&T is taking this route because they have over 2000 ATMs to address.

If undue burden is going to be your claim, that’s fine.  But you should have documented the claim long ago, and you would still be wise to show a paper trail that demonstrates ATM upgrades were in your strategy, and that the “surprise” of other higher priority projects (such as the June 2011 Authentication Supplement) took precedence.

As far as the legal threats we’ve been hearing about . . . . . we will soon find the answer to the question:  Are ambulance-chasers becoming ATM-chasers?

——————————————-——————————————————————–————————-

Dan Hadaway CRISC, CISA, CISM
Founder and President, Infotex

——————————————-——————————————————————–————————-

“Dan’s New Leaf” is a “fun blog to inspire thought in the area of IT Governance.”

 

 

 

Latest News
    How Do We Know What We Know? Making Sure You Can Understand What Happened in an Incident. Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . . Until I reclined on my front yard, looking at the sky, following the instructions on how not to look […]
    Another awareness poster for YOUR customers (and users).  Now that we have our own employees aware, maybe it’s time to start posting content for our customers! Download the large versions here: Awareness Poster (Portrait) Awareness Poster (Landscape)   You are welcome to print out and distribute this around your office. Interested in one of ours […]
    President Biden recently signed a bill tasking the agency with evaluating the unique risks that schools face… An article review. Taking note of the unique challenges educational institutions face in securing their networks, President Biden has signed a bill into law directing the Cybersecurity and Infrastructure Security Agency (CISA) to look into ways that they can […]
    Thanks for being interested in our Technology Planning Webinars! This year‘s annual update to our annual Technology Planning webinar will include a panel discussion, a review of the previous years’ movies that are already available, and a discussion about alternative tactics that have arisen from recent conferences as well as the impact of the AIO […]
    Welcome Cybersecurity Conference Attendees! Thanks for joining us for the Cybersecurity Conference today! We have created this page for you to have access to the deliverables from Dan’s talk.  
    What you need to know for compliance coast-to-coast. Back in 2020 we posted an article containing links to data breach laws from each state, and it has proven to be one of our more popular posts.  Because laws surrounding the use (and abuse) of technology are always evolving, we thought it was worth taking another […]
    Why It Rhymes With SEEM (And its Not the I Before E Rule) Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . . It’s the Gestalt. The idea that the whole is greater than the sum of it’s parts. That’s not something that is often brought […]
    Another awareness poster for YOUR customers (and users).  Now that we have our own employees aware, maybe it’s time to start posting content for our customers! Download the large versions here: Awareness Poster (Portrait) Awareness Poster (Landscape)   You are welcome to print out and distribute this around your office. Interested in one of ours […]
    Questions about China’s new disclosure laws only highlight the uncertainty about disclosure in general… An article review. China recently made waves in the security world by announcing a new set of data security laws, one of which has added new fuel to a long running debate: how and when should security vulnerabilities be disclosed…and to […]