Lost among CARD, CCFFA (Interchange), FAROCA (Overdraft), CFPA and all of the other regulatory and legislative alphabet soup that we all face is a little publicized court case that could impact us all. Several years ago the American Federation of the Blind assisted in a suit seeking that U.S. currency have features added that make denominations distinguishable by those individuals that are visually impaired. The court found in the Federation’s favor and instructed Treasury that as each note is redesigned a feature be added. The $1 note is exempted from this ruling. As a matter of public policy, this makes sense. Virtually every other country in the world has provided some means for the visually impaired to distinguish the denominations of their currency. Recently Treasury announced that it will not appeal the ruling.
The $100 note was already in redesign and will not be impacted in the current cycle. Treasury intends to seek comment later this year on design features and will incorporate the features into the next note redesigned. The two most commonly discussed features are changing the size of the notes or adding a brail feature to the note.
• Changing the size of the note by denomination would be fairly dramatic. It would impact ATM’s and their associated canisters/dispensers as well as virtually every cash register, cash drawer and other piece of cash handling equipment in the U.S. The ATM manufacturers should be well positioned since they dispense notes of varying sizes in many other countries using much of the same equipment in use in the U.S. There would likely be a need for upgrades and adjustments on ATM’s. Retailers and teller/vault operations would face more significant and expensive challenges.
• Adding a brail feature should be less disruptive. The challenge will be creating a feature that does not impact automated counters and dispensers yet is durable over the life of the note. Undoubtedly some adjustment or upgrade of existing teller, vault and ATM equipment may be needed. Given the sheer volume of such equipment, even testing will be an expensive proposition.
CO-OP Financial Services is monitoring this initiative closely, will comment to Treasury in coordination with you and other credit union advocates, and above all will keep you informed of requirements as they evolve. Our goal will be to support the public policy position but encourage implementation that lessens impact and costs to credit unions. Depending on the feature added, CO-OP intends to work with the ATM vendors to coordinate and aggregate for purposes of a credit union system implementation. On this issue, as with other payments related topics, CO-OP intends to provide leadership in guarding the interests of our member credit unions.
Expense of re-designing ATM cash cassettes and all cash handling components of the ATM — could be a good time to look into leasing new ATMs instead of retrofitting old ones.