The document outlines the increasing importance of digital accessibility for financial institutions, driven by COVID-19 and a lack of clear ownership for accessibility responsibilities within organizations. It emphasizes the need for corporate policy, compliance with laws like the ADA, and proactive measures to ensure digital products are accessible, while also highlighting the economic benefits of inclusivity. Additionally, it discusses trends in compliance and the necessity of ongoing accessibility support to mitigate legal risks and improve customer engagement.

1. Accessibility 101
for
Financial
Institutions

2. The World We’re In
COVID-19
Increased awareness of the need for digital accessibility
• 83% of all respondents said that “COVID-19 has raised the profile and importance of digital
channels for their organization” and
• 62% reported that “COVID-19 has raised the awareness and impact of accessibility on the
digital channel.”
• New opportunity to spread accessibility awareness and accountability across teams.
• Increased work on this allows teams to work together & adapt a unified effort
QA Vector Research

4. Who Owns This?
“Business often says legal should own accessibility, legal says it
is for product and product says it is for UX. Nobody owns accessibility.”
- User Experience Director, Global US Insurer
“Without a mandate from legal, getting specific funding for accessibility
is difficult.” - User Experience Director, Nation
Holistic Corporate Ownership for accessibility is critical.
This will enable firms to rationalize spend, reduce internal friction and
have a proactive plan to reduce customer complaints ( aka: reduce risk)

5. Program Structure for Financial Firms
Corporate Policy
• Human Resources
• Documents & Staff Environments
• Internal System Accommodations & Remote work
Digital Products
• Websites, On Line Banking, Mobile Apps
• PDF’s & Videos
• Updating Content
Third Party Vendors
• Loyalty Programs
• Careers Page
• Plug-ins

6. Risk Mitigation
• Post Accessibility Statement
• Third Party Vendor Contracts
• Audits & Governance
• Defense Strategy

7. Compliance Governance
• Setting a Plan
• Tracking Progress
• Choosing Wisely

8. Defense Strategy

9. What to do in 2021
• Draft an Accessibility Inclusion Policy
• Get Website Statements Posted
• T’s & C’s of Mobile Apps
• Customer Service Training
• Loyalty Programs
• Careers Page
• Plug-ins
• Updating Content

10. What Not to do
• Panic
• Install and Overlay
• Nothing

11. Looking Ahead into 2022
• Firm Foundation
• Plan to Pay for Accessibility
• Protect Investment Made

12. What Is Digital
Accessibility?

13. The inclusive practice of removing
barriers that prevent interaction with
websites, apps and enterprise systems
for people with disabilities.
Accessibility in the
Digital Age
13

14. Visual
Types of Disabilities
CONFIDENTIAL
Cognitive
Physical
Auditory

15. People With Disabilities
* CDC https://www.cdc.gov/
* The Global Economics of Disability - Fifth Quadrant
Analytics
61 m
US Population with Disability
1/3
US families have
at least one member
with a disability
1 in 10
men are
color blind
$544 billion
Spending power
1 B
Disability affects more than one billion people
worldwide

16. Business Case for Accessibility
Social Responsibility
• Equitable Access helps close the digital divide
• Improves quality of life for millions
Maximize Profits
• Build goodwill toward your brand
• Welcome everyone into your audience
• Retain the aging baby boomers as customers
Financial
• Up to a 10:1 savings if done with new digital product builds
• A360’s Proactive Solutions can reduce costs and reduce risk
Legal Risk
• Any plaintiff firm can sue any company for a non-compliant site
• You are not safe or “done” just because you settle with one plaintiff
• Government, Medical and Public Education should already be compliant
CONFIDENTIAL

17. Bring your content to life.
For everyone.
Digital content correctly designed and coded,
offers access to information & functionality via
the assistive technology devices that people
with disabilities use to gain access.
Assistive Technology
CONFIDENTIAL

18. Demo
Scree
n
Reade
r
https://youtu.be/Q1gHxM1nP00
CONFIDENTIAL

19. Accessibility
and The Law

21. Accessibility and the Law
Rehabilitation Act of 1973
How the law is applied to the digital space
Americans with Disabilities Act of 1990
Title I: Employment
Title II: Public Entities
Title III: Accommodations
A11y Global Initiatives
World Wide Web Consortium (W3C)
Web Accessibility Initiative (WAI)
Web Content Accessibility Guidelines (WCAG 2.0 & 2.1)
CONFIDENTIAL

22. Section 504
Federal law protects the rights of individuals with disabilities in programs and activities that receive Federal
financial assistance
Section 508
Requires Federal agencies to make their electronic & information technology (EIT) accessible to people with
disabilities
The Rehabilitation Act of 1973
CONFIDENTIAL
As amended in 1998

23. • ADA Title I, Employment
• ADA Title II, Public entities
(federal, state and local government, medical & public education)
• ADA Title III, Public Accommodations
(stores, banks, theaters, bars, restaurants, etc.)
Americans with Disabilities Act of 1990
CONFIDENTIAL

24. Public Accommodations
WHAT IS THE SCOPE OF PUBLIC ACCOMMODATIONS COVERED
UNDER TITLE III OF THE ADA?
Generally, courts have held that a website of a public entity is also covered by Title III
of the ADA and in cases of online-only businesses, it is also widely accepted after court
rulings.
Companies now understand it is possible to allow everyone into the digital audience to
access their goods and services.

25. W3C
The World Wide Web Consortium is
an international community that
develops open standards to ensure
the long term growth of the Web.
www.w3.org
WCAG
Web Content Accessibility Guidelines
https://www.w3.org/WAI/WCAG20/quickref/

26. Information and UI components must be
presentable in ways users can perceive
WCAG Principles
UI components & navigation must
be operable by those using
assistive technology
Information and UI must be
understandable to people
with disabilities
Content must be interpreted
consistently and reliably by
users and assistive
technologies
UNDERSTANDABLE
OPERABLE
PERCEIVABLE
ROBUST

27. Section508 Compliance
•1998 to 2017
• Very specific about issues
• Severely limits ways to fix
• Overly prescriptive and rigid
WCAG 2.0 AA
• Clear guidelines
• Excellent supportive documents
• Not only one way to fix code
• Future-proof
• Flexible and adaptable
What are the Guidelines?
Jan. 2017: Section508 refresh notice
Jan. 2018: WCAG 2.0 AA in effect!
CONFIDENTIAL
WCAG 2.1* AA
• Builds on 2.0
• 3 brand new guidelines 17 / 12 are
AA
• To address the input modalities that
did not exist when WCAG 2.0 was
released in 2008
Pointer Accessible
Additional Sensor Inputs
Speech
* Not all Clients need these new elements tested, simply because they are not
present on their sites / products and Clients need to verify the presence of
these, as it is not always obvious or apparent.

28. Office of Civil Rights
Department of Justice – DOJ
Demand Letters
Lawsuits In Federal or State
Courts Class Action
• Engage independent approved vendor for a live-user audit
• Publish an Accessibility Statement
• Solicit feedback regarding accessibility
• Offer Improved telephone support
• Technical Training for development teams
• Continue to Monitor websites to maintain compliance
• Designate Accessibility Coordinator from the Dev Team
•Obtain a Letter of Conformance from the Auditor
Enforcement:
CONFIDENTIAL
The Common Elements of
DOJ Settlements

29. • Section 504 & 508 Public Entities have been Required since 1998 ~ most are not
compliant.
❖ Government
❖ Healthcare
❖ Education
• 21st Century IDEA Act
• EEOC Title I of the ADA is Employment Claiming you are an “EEOC” Employer …. ?
• Unruh Civil Rights Act ~ $4,000 per access violation plus attorneys fees
• The Accessibility for Ontarians with Disabilities Act (AODA) 2005
• The EU Directive
• CCPA WCAG 2.1 in 2021
CONFIDENTIAL
Regulations & Enforcement

30. •Your competition is paying attention ~ get going on this
•Live User audits replaced automated scanning tools
•New websites are frequently targeted by plaintiffs
•General public is demanding equitable access
•Companies are holding digital agencies accountable for compliance
•Plaintiff law firms are incredibly active
•Settling one lawsuit does not prevent another; must fix your digital products
Trends in ADA Compliance
CONFIDENTIAL

31. Becoming Digitally
Accessible

32. What to Include in Your Accessibility Testing
plan
• Corporate Website
• Mobile Apps & OLB
• Product Demo Videos
• Investor Information & Portfolio Briefs
• Third Party Software
• New Builds

33. VPAT

34. Methods 34
1.Live-User Audits
Only way to determine accessibility & compliance
2.Other So-Called Solutions
Add-ons or Over-lay Tools & the results of live testing these
Scanning Tool errors & the limitations of all SaaS scans
3. “Separate but Equal” websites
Typically very expensive, unnecessary & poorly received
Fix the site you have why pay for upkeep of 2 websites?
- Live User Audit Results of these
Note: Ruling against Scandinavian Airlines
CONFIDENTIAL

35. Scanning Tools Alone
Leave You Vulnerable
CONFIDENTIAL
Reports are not informative or accurate
enough for developers to use for
remediation
They all return false positives
Lack the recommended fixes to specific
accessibility problems
Tool
% Found of the
143 known issues
SortSite 40%
Tenon 32%
AChecker 32%
SiteImprove 29%
aXe 29%
ASLint 28%
FAE 28%
WAVE 27%
HTML_CodeSniffer 20%
Google ADT 17%
EIII 16%
Nu Html Checker 9%
https://alphagov.github.io/accessibility-tool-audit/
Free tools return about the same
scores
Keep in mind: Only 20-25% of WCAG Success Criteria can be Scanned for
Of the 20-25% found in scans

36. Audit Process
Remediation
Support
Maintain
Audit
Your Environment
Reporting on Compliance
scope | advise
training | live QA
re-check | monitor | a new
build
CONFIDENTIAL
Letter of Conformance

37. New Build Design & Development Process
Build Launch
Accessibility In
Preview
New Designs Accessible & Compliant
support | advise train | test | QA support | monitor
CONFIDENTIAL

38. Partner With A360
Enabl
e
Leverag
e
Accessible Processes
across all businesses
Establish
A360 Seeks Like- Minded
Platforms & Third Parties for
referral network
Market your New Competencies paired
with A360’s Validation & Deliverables
CONFIDENTIAL

39. Superior Vendor
Litigation
Support
A360 HUB
Governance System
Knowledgebase &
Training
Disrupted Market with
Rebuttal Reports &
Litigation Support
CONFIDENTIAL
Proven
Process
Single Site to Hundreds
within One Company

40. Shift Left
Include accessibility at the beginning of
your design/build process
Source: IAAP

41. KEY TAKE AWAY:
Making your website Digitally Accessible should
be viewed as a process, not a one-time project
• Don’t let the time and money go to waste
• Reduce risk of costly lawsuit litigation
Ongoing Accessibility Support 41

42. Thank You!