The Road to Financial Inclusion
Those of us working in the disabilities sector and those who live with the reality of disability know how difficult it is for persons with disabilities to even open bank accounts independently, and for those who are allowed to open bank accounts on their own, access to added services like ATM cards, chequebooks, internet banking — facilities which many of us take for granted — becomes a matter of discretion of bank managerial staff. The CIS Report on Banking Accessibility is a seminal document on the problems being faced on accessibility to banking, and it was hoped that the Reserve Bank of India would take cognizance of the numerous issued raised within it.
On May 21, 2014, the Reserve Bank of India issued a notification mandating all scheduled banks to take necessary steps to provide all existing ATMs / future ATMs with ramps for the same to be accessible for persons with disabilities, and provided further that the height of the ATMs should not create an impediment in their use by wheelchair users. The onus is on banks to provide this, and in cases where such changes are not practicable, this requirement may be dispensed with, for reasons recorded and displayed in branches or ATMs concerned. The requirements for ramps at entrances is also extended to bank branches (wherever feasible). The notification also notes the failure of Banks to ensure that at least 1/3rd of all their ATMs are "talking" ATMs with Braille keypads as per the 2009 Circular and now mandates that all ATMs installed from July 1, 2014 shall be talking ATMs with Braille Keypads.
The 2014 Notification goes one step forward and makes special provisions for providing magnifying glasses for persons with low vision in order to assist them in the carrying out of banking transactions. Banks should maintain a list of facilities for persons with disabilities and make this information available for customers prominently. On the May 27, a similar Notification, extending similar provisions to Regional Rural Banks, was published.
What does this mean for accessibility and banking? Definitely, the circulars come as a big boost to accessibility, particularly with regard to ATM facilities. ATM Machines which are designed to accommodate persons with disabilities do make a huge difference, though many, many persons have reported not even being given access to these facilities on account of their disabilities which has not been addressed in these circulars.
Additionally, it does not appear that non compliance is actionable, as Banks are merely advised to report the progress made in this regard periodically to their respective Customer Service Committee of the Board and ensure compliance. As pointed out above, reasons for non compliance are merely to be recorded and displayed. The procedures to approach the Ombudsman do not include accessible measures, and this continues to allow bank staff to act with impunity in denying banking facilities for persons with disabilities.
Despite actively intervening in the eventual Report of the Technical Committee on Banking of the RBI, disability rights activists have found that the banking industry has not been receptive to the needs of persons with disabilities. From this background, the RBI Notifications are a welcome start, though slightly premature — what is of utmost urgency on the part of the RBI is a categorical statement that no person with disability who comes to the bank to open a bank account will be denied access to the same. Additional tools which can be extremely beneficial to persons with disabilities, including mobile and internet banking, must be made accessible and available to persons with disabilities. It is also important for basic training on disability and communication be made part of syllabus for training of banking officials, and that regular interactions and training is encouraged for bank officials. It would be useful for all bank branches, and all departments of the RBI, to have an accessibility officer, a bank official given the additional responsibility of ensuring accessibility of the bank branch or the Department as the case may be, who is given specialized training in matters relating to accessibility. This would go a long way in ensuring that financial inclusion leaves no one behind.