Statements for the Disabled

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Question:

We had a member inform us it was the "law" that we supply privacy notices in braille. We do supply privacy notices to ALL members on the Internet, in our statement once a year and to All new members when an account is opened. Must we now ensure that we have a privacy statement for our disabled members, e.g., deaf, blind, etc.?

Answer:

This demand is probably based on the Americans with Disabilities Act. In fact, ADA requires barrier-free access to products, services and related information and disclosures. It does not, however, dictate a particular accommodation to overcome a customer's disability. Instead, businesses are free to use any reasonable means. Many blind people do not read braille. In these cases, some form of audio recording of the privacy disclosure would be more suitable.

First published on BankersOnline.com 1/3/05