You might not think about it a lot, but do you ever wonder whether banks are compliant with the Americans with Disabilities Act? They are certainly a lot more compliant than they once were, but they still have a long way to go, and they continue to be the victim of lawsuits alleging ADA violations.

Banks have already spent hundreds of millions of dollars to get their ATMs into compliance with titles II and III of the Americans with Disabilities Act, which requires them to make all ATMs fully accessible to the visually impaired. But many aren’t done, and those that haven’t become fully compliant are open to potentially millions more in litigation costs. Bank defense attorneys say these lawsuits could pop up all over the country.

Banks have had their share of problems with regulations and standards for the visually impaired since 1990, when the ADA became law. The current regulations, which were issued and approved by the Department of Justice in 2010, require that ATMs have audio jacks for voice instructions, provide for privacy for visually impaired customers, such as the blacking out of screens when audio components are used and that they contain braille instructions, among other things.

While the banking community has been working with the visually impaired community for quite some time, a whole host of banks have settled lawsuits with the visually impaired community. These lawsuits continue to happen.There are roughly 405,000 ATMs in the U.S., according to the Aite Group. Banks own about 285,000 of those, and independent service organizations own the remainder.

To bring an ATM into compliance, banks must either change the entire machine or replace hardware parts or software components. ATMs can typically last up to 20 years and many older ones do not offer the functionality that the newer ones do, so upgrading them requires installing an entirely new machine. And here is the kicker: a new state of the art ATM costs approximately $50,000. It can cost thousands just to upgrade the software in ATMs.

There are nearly three million visually impaired people in the U.S. The last thing the banking industry needs right now is to face a slew of class action lawsuits. This situation shows how one more industry is facing lawsuits associated with compliance with the ADA more than 20 years after it was passed.