CREDIT CARD ACCOUNTABILITY RESPONSIBILITY 

AND DISCLOSURE ACT OF 2009 

REPORT ON EMERGENCY TECHNOLOGY FOR USE WITH ATMs 

April 2010 

Submitted by: 

Bureau of Economics 

Federal Trade Commission
Table of Contents

Executive Summary............................................................................................................. i

I. Study Required Under the Credit Card Act of 2009............................................. 1 

II. Nature of Available Data.......................................................................................... 2 

A. Background............................................................................................................. 2 

B. Data from the Department of Justice ...................................................................... 4 

C. Data from Local Law Enforcement Agencies ........................................................ 5 

D. Data from Trade Associations and Businesses ....................................................... 7 

E. Summary................................................................................................................. 8 

III. Emergency-PIN Technology .................................................................................... 8 

A. Description and Use............................................................................................... 8 

B. Likelihood of Decreased ATM-Related Crime or Injury.................................... 11 

1. Frequency of Crimes Susceptible to Emergency-PIN Use........................... 12 

2. Distressed Customer Responses ................................................................... 13 

3. Law Enforcement Response Times .............................................................. 15 

4. Potential Changes in Offenders’ Practices.................................................... 16 

C. Costs of Use ........................................................................................................ 18 

D. Costs of Implementation..................................................................................... 20 

1. Bank Cost Estimates ..................................................................................... 20 

2. Potential Suppliers’ Cost Estimates.............................................................. 22 

3. Third-Party Cost Estimates........................................................................... 24 

E. Summary.............................................................................................................. 28 

IV. Alarm Button Technology...................................................................................... 28 

A. Description and Use.............................................................................................. 28 

B. Likelihood of Decreasing ATM-Related Crime or Injury .................................... 31 

C. Costs of Use .......................................................................................................... 34 

1. Increased Physical Danger............................................................................ 34 

2. False Alarms ................................................................................................. 35 

D. Costs of Implementation....................................................................................... 36 

V. Conclusion ............................................................................................................... 37 
i 

Executive Summary 

Every year millions of transactions are conducted using the nation’s estimated 

400,000 automated teller machines (“ATMs”). Before, during, or after withdrawing cash 

from an ATM, a customer may be the target of a robbery or other violent offense. The 

Credit Card Accountability Responsibility and Disclosure Act of 2009 (the “Act”) 

mandates that the Federal Trade Commission (“FTC”) provide an analysis of any

technology, either currently available or under development, which would allow a 

distressed ATM user to send an electronic alert to a law enforcement agency. In 

particular, the FTC was directed to evaluate the efficacy of so-called “emergency-PIN” 

and “alarm button” technologies by: (1) providing an estimate of the number and 

severity of any crimes that could be prevented by the availability of these devices; (2) 

estimating the costs of implementing such devices; and (3) comparing the costs and 

benefits of at least three types of such devices. Although FTC staff determined that the 

requisite data to evaluate the efficacy of these technologies are not available, staff 

nevertheless conducted a review based on other materials to provide a sense of the value 

of the technology. 

FTC staff reviewed various ATM trade press reports and academic studies and

contacted a range of entities – several government agencies, a number of major, private 

financial institutions, other firms, trade associations involved with ATMs and ATM 

security, and suppliers of the technologies – that staff believed to be most likely to have 

relevant data on ATM crimes and security technologies. None of these sources, however, 

provided data that would permit the analyses specified by the Act. Most fundamental, 

FTC staff learned that emergency-PIN technologies have never been deployed at any 

ATMs, and alarm buttons have been deployed only at very few ATMs. None of the 

information collected indicated that any similar technology is currently in use for a 

distressed customer to electronically alert local law enforcement. FTC staff found that 

data on ATM-related crimes and the costs of these emergency technologies – whether 

from government or private sources – are very limited and are inadequate for a rigorous 

analysis. 

The information staff received and staff’s review of the state-level legislative 

history relating to these issues, however, raise questions about whether the benefits of 

emergency-PIN or alarm button technologies would exceed the associated costs of 

implementation for most ATM-related crimes. The available information suggests that 

emergency-PIN and alarm button devices: (1) may not halt or deter crimes to any 

significant extent; (2) may in some instances increase the danger to customers who are 

targeted by offenders and also lead to some false alarms (although the exact magnitude of 

these potential effects cannot be determined); and (3) may impose substantial 

implementation costs, although no formally derived cost estimates of implementing these 

technologies are currently available. The anecdotal evidence that the staff relied upon, 

however, does not allow for any definitive conclusions regarding the efficacy of the 

reviewed emergency-PIN or alarm button systems to affect ATM crimes.
1 

I. Study Required Under the Credit Card Act of 2009 

Section 508 of the Credit Card Accountability Responsibility and Disclosure Act 

of 2009 (“the Act”)1 mandates that the Federal Trade Commission (“FTC” or 

“Commission”) conduct a study (hereafter “the study”) on “the cost-effectiveness of 

making available at automated teller machines [“ATMs”] technology that enables a 

consumer that is under duress to electronically alert a local law enforcement agency that 

an incident is taking place at such [ATM] . . . .”2 

The Act specifies two such technologies to be evaluated: 

 “an emergency personal identification number that would summon a local 

law enforcement officer to an [ATM] when entered into such [ATM] . . .”3

 “a mechanism on the exterior of an [ATM] that, when pressed, would 

summon a local law enforcement [officer] to such [ATM].”4 

The first security measure is commonly referred to as “reverse-PIN” or “emergency-PIN” 

technology and the second as “alarm button” technology. 

Under the Act, the study should include: (1) “an analysis of any technology 

[allowing a distressed ATM user to electronically contact a law enforcement agency] that 

is currently available or under development”; (2) “an estimate of the number and severity 

of any crimes that could be prevented by the availability of such technology”; (3) “the 

estimated costs of implementing such technology”; and (4) “a comparison of the costs 

and benefits of not fewer than 3 types of such technology.”5

 The Commission is to issue 

 

1

 Credit CARD Act of 2009, Pub. L. 111-24, § 508. 

2 Id. at § 508(a). 

3 Id. at § 508(a)(1). 

4 Id. at § 508(a)(2). 

5 Id. at § 508(b)(1)-(4).
2

a report of the findings of the study no more than nine months after the date of the 

enactment of the Act. The report is also to include “such recommendations for legislative 

action as the Commission determines appropriate.”6 

FTC staff found that a few security systems allowing a distressed ATM customer 

to contact a local law enforcement agency electronically have been developed. However, 

no federal or state laws or regulations currently require the adoption of such measures, 

and FTC staff found no evidence that any of these proposed technologies have been 

deployed to any significant extent. 

Staff obtained a variety of anecdotal data, but was unable to find data sufficient to 

conduct a rigorous study of the issues set forth in the Act. This report describes the 

staff’s efforts to collect the data, discusses the anecdotal data received, and concludes, 

based on that anecdotal data, that the benefits of these ATM security technologies might 

not exceed the associated costs. At the same time, this anecdotal evidence does not allow 

for any definitive conclusions regarding the efficacy of emergency-PIN or alarm button 

systems to affect ATM crimes. 

II. Nature of Available Data 

A. Background 

FTC staff investigated a broad range of potential information sources regarding 

ATM crime and security technologies that would allow staff to perform a credible study. 

As mandated by the Act, FTC staff consulted the United States Department of Justice 

(“DOJ”) and the Secret Service; it also contacted the Federal Deposit Insurance 

 

6 Id. at § 508(c).
3

Corporation (“FDIC”).7

 FTC staff searched ATM trade industry publications and the 

academic literature related to ATM crime. Staff researched state laws and reviewed the 

records of states’ consideration of legislation, and contacted state and local law 

enforcement as well as municipalities that it identified as having mandated installation of 

alarm buttons (along with cameras and other safety measures). 

FTC staff asked members of industry that might have relevant data whether they 

maintain information on the security technologies installed at ATMs, as well as the 

crimes committed at those locations. Staff contacted a manufacturer of ATMs and 

provider of ATM security solutions, a major provider of electronic payment software, and 

two trade associations whose members include ATM manufacturers, banks, payment card 

networks, and information processors, among others. Staff also obtained information 

from three holders of patented ATM security technologies. Finally, FTC staff directly 

contacted private financial institutions (referred to here for simplicity as “banks”). 

FTC staff determined that no public or commercial organization appears 

systematically to collect or to have collected the ATM-related data that would be 

necessary for the Commission to conduct a rigorous study. First, as discussed below, no 

ATMs employ or have employed an emergency-PIN system, and very few employ an 

alarm button system. Staff found no indication that any other technology with the 

capability of allowing a distressed ATM customer to contact electronically a local law 

enforcement agency exists. Thus, it was not possible to derive a formal (i.e., statistical) 

estimate of the number or severity of crimes deterred as a result of an emergency-PIN or 

 

7 Id. at § 508(a). 
4

alarm button system, or to infer the effects of such a system from any similar technology 

employed at ATMs.

Second, neither the DOJ, the Secret Service, nor the FDIC track data on the 

specific security devices installed at individual ATM locations or specify ATM crimes 

where the victim is “under duress” during an ATM withdrawal. Thus, these government 

agencies do not have reliable data on the amount of crime that an emergency-PIN or 

alarm button system might affect. The Secret Service and FDIC both track some data on 

the incidence of ATM fraud offenses, which would not be deterred by emergency-PIN or 

alarm button technology.8

 

Some of the respondent banks appear to track information on the security devices 

and crimes committed at their ATMs. According to one of these banks, ATM fraud is 

much more common than crime committed directly against ATM customers who are in 

the process of attempting to withdraw cash.9 

B. Data from the Department of Justice 

The DOJ, through the Federal Bureau of Investigation (“FBI”) Bank Crime 

Statistics (“BCS”) program, compiles some data on ATM crimes. The data have 

deficiencies, however, that render them unsuitable for the study mandated by the Act. 

The FBI’s BCS data classify a reported offense at an ATM as a robbery, burglary, or 

 

8

 Fraud crimes include the insertion of a “skimmer” device into an ATM card reader in 

order to steal a customer’s PIN number as well as attempts to remotely “hack” into the 

software systems running ATMs and/or their networks in order to electronically divert 

funds into another account. Fraud offenses are not those in which a victim is “under 

duress;” rather, such crimes come to the victims’ attention only after they have already 

been committed. Thus, adoption of an emergency-PIN or alarm button system would be 

expected to do little in deterring the incidence of ATM fraud. 

9

 Telephone Interview with Jonathan Velline, Senior Vice President, ATM and Store 

Strategy, Wells Fargo (September 25, 2009). 
5

larceny. Most of these crimes are burglaries, which are offenses against property or 

“property crimes,” as opposed to crimes against persons, which are also referred to as 

“violent crimes.” ATM robbery, which is a violent crime, is the only offense category in 

the BCS data that emergency-PIN or alarm button technologies might be expected to 

affect. 

Most of the ATM robberies captured in the BCS data involve traditional bank 

robberies in which the offender had a bank employee remove money from an ATM 

located at the banking site during the course of the robbery.10 BCS data do not capture 

robberies committed while a bank customer attempts to withdraw funds from an ATM 

because those robberies are not federal offenses.11 As a result, the FBI’s BCS data do not 

provide a credible estimate of the number or severity of ATM crimes committed 

involving bank customers, and thus they do not provide an estimate of ATM crimes that 

could be deterred by ATM security devices.12 

C. Data from Local Law Enforcement Agencies 

 FTC staff also sought ATM crime data from local law enforcement agencies. 

While some police agencies apparently have begun to track more carefully crimes 

involving the use of ATMs, these data do not appear to be useful for the purpose of 

 

10 E-mail from Bradley V. Bryant, Unit Chief, Violent Crimes Unit, U.S. Federal Bureau 

of Investigation to FTC staff (July 15, 2009). 

11 Id. 

12 The FBI’s BCS crime statistics consist only of reported ATM offenses, and it is 

unknown to what extent the underlying reporting rates correlate with actual offense rates. 

Furthermore, these data only correspond to those ATMs that are owned by an FDIC 

insured institution (or the National Credit Union Administration in the case of a credit 

union). Some ATMs are not owned and operated by financial institutions, but there is no 

publicly available information regarding what proportion of the nation’s ATMs are 

owned by entities other than banks. In any event, these facts suggest that the BCS data 

do not constitute a random sample of ATM crimes. 
6

conducting the study. For example, the reports used by the Los Angeles Police 

Department (“LAPD”) include an option to indicate whether a reported crime 

corresponded to an ATM robbery. However, the LAPD states: “The reports have a 

specific box for an ATM robbery, that was originally the focus, but this fact alone will 

not tell you if the transaction was forced or after the monies had been withdrawn . . . .”13 

Whether the crime occurred before or after the money is removed from an ATM 

is critical in evaluating the types of ATM security devices specified in the Act.14 A 

customer who is confronted by a criminal only after he or she has withdrawn money from 

an ATM will not be able to activate an emergency-PIN, and, if confronted after moving 

away from the ATM, may not be able to activate an alarm button device. The LAPD 

indicates that only a detailed study of individual police reports could determine the 

precise circumstances surrounding these reported robberies.15 Joseph Zingher, a patent 

holder of one emergency-PIN technology (discussed below), attempted to obtain ATM 

location-specific crime data from police jurisdictions that he identified as tracking these 

data, but those agencies would not examine the individual police records.16 

 

13 E-mail from Alfred Pasos, LAPD, to FTC staff (December 1, 2009). 

14 As discussed further below, one type of emergency-PIN technology is “reverse-PIN.” 

Bank of America notes that “[an]other problem with reverse PIN to consider is that it 

assumes the customer is approached prior to entering their PIN as opposed to after they 

have started their transaction. There has been no study to determine whether the ATM 

robberies are committed before or after the customer enters their PIN.” E-mail from 

Marc Lyons, Bank of America, to FTC staff (October 2, 2009) (Marc Lyons E-mail). On 

the other hand, the perpetrator may have some incentive to demand funds before the 

transaction is completed so as to force the customer to withdraw the maximum amount of 

funds allowed by the ATM. 

15 Pasos e-mail, supra note 13. 

16 Telephone Interview with Joseph Zingher, President, Zi Cubed Inc. (December 3, 

2009). 
7

D. Data from Trade Associations and Businesses 

The staff contacted two trade associations affiliated with the ATM industry, a 

manufacturer of ATMs and provider of ATM security solutions, and three holders of 

patented ATM technologies, including two emergency-PIN providers and one alarm 

button provider. None of these entities was able to provide sufficiently detailed data on 

ATM crimes for use in the study. 

FTC staff also contacted several of the largest banks in the U.S. to determine any 

data they might have for the study. Staff sent detailed questionnaires to five major banks 

regarding the tracking of ATM offenses, the security devices installed at ATMs, and the 

costs of implementing an emergency-PIN or alarm button system. Three banks 

responded to the FTC inquiries.17 However, these banks indicated that they did not have 

sufficient data for the study. 

 

17 The FTC staff’s data collection efforts were conducted within the parameters of the 

Paperwork Reduction Act 44 U.S.C. §§ 3501 et seq., which limits the staff’s ability to 

obtain the same information from more than nine separate entities. The FTC staff 

identified the specific banks to be contacted from a list of the largest bank holding 

companies maintained by the U.S. Federal Reserve System. See 

http://www.ffiec.gov/nicpubweb/nicweb/Top50Form.aspx. When responses were not 

received, staff placed phone calls or e-mails with the next largest company down on the 

aforementioned list. The three responses that staff received come from the first, second, 

and fourth largest banks in the U.S. in terms of total assets, id., and are thus likely to 

provide a relatively accurate assessment of the current state of ATM security 

technologies and the extent of their adoption given the scale of their ATM networks. 

Furthermore, as discussed below, patent holders Mr. Zingher and the seller of 

ATMOnGuard indicated that no U.S. banks are currently using (or have ever used) 

emergency-PIN technology, which would render any further attempts to obtain data from 

banking institutions moot. Zingher Interview, supra note 16; Telephone Interview with 

Danalyn Russikoff, ATMOnGuard (February 1, 2010). 
8

 E. Summary 

Because of the lack of sufficient data, FTC staff could not conduct a credible 

study of the issues specified in the legislation. The following discussion of the anecdotal 

information obtained addresses, in turn, emergency-PIN technology and alarm buttons. 

III. Emergency-PIN Technology 

A. Description and Use 

An emergency-PIN (personal identification number) works by allowing a 

distressed customer at an ATM to enter some variant of their regular bank card PIN in the 

keypad to electronically alert a law enforcement agency. One variant of this technology, 

known as “reverse-PIN,” has been rumored to have been available at ATMs for some 

time despite never being implemented, falling into the realm of urban legend.18 Under a 

reverse-PIN system, a distressed ATM customer with a bank card PIN of, for example, 

“1234” would simply enter this number backwards, or “4321,” which in turn would 

automatically send an electronic relay message to a dispatch center or the police, alerting 

them of the customer’s location.19 

 

18 See, e.g., http://urbanlegends.about.com/library/bl_reverse_pin.htm (noting that the 

availability of a reverse-PIN system at ATMs is only a rumor). 

19 A commonly cited criticism of the reverse PIN concept is the fact that many bank 

customers have “palindromic” PINs, such as “2222” or “4334,” which are the same when 

reversed. The palindromic PINs thus may not provide for an alert to the police or may 

result in an accidental alert to the police. Mr. Zingher’s SafetyPIN system (discussed 

below) offers a solution to these PIN combinations; in the former case a “plus one” 

algorithm is adopted (the reverse PIN associated with “2222” would become “3333”), 

while the latter uses an “inside out” algorithm (“4334” would become “3443”). 
9

An ATM reverse-PIN system called “SafetyPIN” was invented by Joseph Zingher 

and patented in March 1998.20 According to Mr. Zingher, SafetyPIN is a simple 

computer code “that would recognize reversed, inverted, or otherwise altered [PINs] as a 

distress signal, and [instruct] the teller machine to call the cops.”21 The electronic 

message relayed to an alarm company dispatcher would contain “the card holder’s name, 

identifier and location. (The identifier is usually their driver’s license, date of birth + full 

name, etc).”22 For several years, Mr. Zingher attempted to sell SafetyPIN to banks in 

Illinois, Georgia, and Florida, but his attempts were unsuccessful.23 Mr. Zingher offered 

to make the product available for free on a trial basis to banks in Kansas, but his offer 

was declined.24 Mr. Zingher reports that he has had no customers for his emergency-PIN 

system and that he is unaware of any other emergency-PIN system in use. 

 

20 Computerized System for Discreet Identification of Duress Transaction and/or Duress 

Access, U.S. Patent No. 5,731,575 (filed April 21, 1997) (issued March 24, 1998) 

(Zingher Patent). Mr. Zingher markets SafetyPIN through his company Zi Cubed, of 

which he is both the sole proprietor and employee. See http://www.zicubedatm.com/. 

21 Forbes: Banking on ATM Safety (January 28, 2004), available at 

http://www.msnbc.msn.com/id/4086277. The idea of a “duress code” associated with 

ATM customer PINs had actually been around for some time before Zingher’s patent. 

For example, on July 30, 1986, Representative Mario Biaggi, a former police officer, 

proposed that ATMs should employ such a code (US Congressional Record at 18232 et 

seq.). In 1987, Representative Biaggi proposed HR 785, which would have had the FBI 

evaluate the idea of an emergency PIN system (the resolution was not debated or voted 

out of committee). 

22 Letter from Joseph Zingher to FTC staff (November 30, 2009) (Zingher Letter).

23 Forbes: Banking on ATM Safety, supra note 21. 

24 Id. 
10

Another emergency-PIN system currently marketed to banks is 

“ATMOnGuard.”25 This device, which Mr. Zingher identified as a competing product,26

does not require a distressed customer to enter a reverse-PIN, but rather to hit a single 

keypad number (i.e., 0 through 9) after the customer’s PIN was entered. The additional 

single keypad entry would indicate whether the transaction was “normal” or being 

conducted “under duress,” which would subsequently send an electronic distress call to a 

dispatch center.27 The ATMOnGuard system has never been deployed at any ATMs in 

the U.S.28 

The respondent banks reported that none of their ATMs currently have installed, 

or have ever had installed, an emergency-PIN system of any sort. The ATM 

manufacturer Diebold confirms that, to its knowledge, no ATMs have or have had an 

emergency-PIN system.29 

Some states have considered legislatively mandating banks to adopt a reverse-PIN 

system. In January 2004, Illinois considered a bill that would have required banks and 

other ATM providers to install reverse-PIN capabilities.30 However, before enactment, 

the bill was amended to make the use of this technology discretionary.31 The issue 

 

25 See http://atmongurard.com/; Computerized Password Verification System and Method 

for ATM Transactions, U.S. Patent No. 6,871,288 (filed February 21, 2003) (issued 

March 22, 2005). 

26 Zingher Letter, supra note 22. 

27 See http://www.atmonguard.com/system/index.htm.

28 Russikoff Interview, supra note 17.

29 Interview with Dean D. Stewart, Director, Self-Service Portfolio Management, 

Diebold, Inc. (March 1, 2010).

30 See S.B. 562, 96th Gen. Assem., Reg. Sess. (Ill. 2003). 

31 See Illinois General Assembly, Public Act 93-0273 (eff. 1-1-04)(“A terminal operated 

in this State may be designed and programmed so that when a consumer enters his or her 
11

remains alive in Illinois; last year, Illinois State Senator Jacqueline Collins introduced a 

bill in the Illinois Senate that would require that ATMs be fitted with reverse-PIN 

systems.32 At present, this legislation remains in committee. 

In 2004, a bill was introduced before the Kansas State Senate Financial 

Institutions and Insurance Committee that would have mandated the implementation of 

reverse-PIN technology at ATMs located in the state.33 This bill was not enacted. In 

2006, the Georgia State Assembly considered a measure that would have adopted 

reverse-PIN systems on ATMs.34 This proposed legislation also was not enacted. 

B. Likelihood of Decreased ATM-Related Crime or Injury 

Despite the unavailability of the data that would be necessary to conduct the study 

mandated by the Act, the preponderance of the extant anecdotal evidence suggests that 

emergency-PIN technologies likely would not have a large impact on ATM crime. First, 

the best available evidence suggests that non-fraud ATM crimes in general occur with 

low incidence. Second, distressed ATM customers may not have the ability or incentive 

 

personal identification number in reverse order, the terminal automatically sends an alarm 

to the local law enforcement agency having jurisdiction over the terminal location. The 

Commissioner shall promulgate rules necessary for the implementation of this subsection 

. . . .”); Public Act 93-0898 (eff. 8-10-04) (“The provisions of this subsection . . . shall not

be construed to require an owner or operator of a terminal to design and program the 

terminal to accept a personal identification number in reverse order.”) (emphasis added). 

The relevant provisions of the two acts are codified at 205 ILCS 616, Section 50(i). 

32 See S.B.1355, 96th Gen. Assem., Reg. Sess. (Ill. 2009). The synopsis of the bill reads: 

“Amends the Electronic Fund Transfer Act. Provides that a terminal operated in the State 

must (instead of may) be designed and programmed so that when a consumer enters his 

or her personal identification number in reverse order, the terminal automatically sends 

an alarm to the local law enforcement agency having jurisdiction over the terminal 

location. Deletes language providing that specified provisions shall not be construed to 

require an owner or operator of a terminal to design and program the terminal to accept a 

personal identification number in reverse order . . . .” 

33 S.B. 333, 2004 Leg., Reg. Sess. (Kan. 2004). 

34 See S.B. 379, 148th Gen. Assem., Reg. Sess. (Ga. 2006). 
12

to activate an emergency-PIN or alarm button device, and in some instances doing so 

might elevate the risk of harm to the customer. Third, police response times may not be 

fast enough to create a high probability that the offender will be apprehended, thereby 

limiting the deterrence effect of such measures with respect to ATM crimes. And fourth, 

offenders may simply change their practices in order to circumvent any additional risk 

posed to them from the deployment of emergency-PIN technologies. 

1. Frequency of Crimes Susceptible to Emergency-PIN Use 

One crucial aspect of the effect of emergency technologies on crime is the 

frequency of crimes that may be susceptible to interruption or deterrence through the use 

of the technology. The little data available indicates that crimes that may be affected by 

the availability of an emergency-PIN system may not be common. Some academic 

research indicates that the majority of ATM robberies do in fact occur only after the 

victim has already withdrawn funds, which would prevent the user’s activation of an 

emergency-PIN device located at the ATM while still under duress.35 Some government 

investigations have concluded that ATM crimes are relatively rare occurrences, even 

though there do not exist any definitive data on the frequency of ATM crimes. For 

example, the Office of Banks and Real Estate of the State of Illinois concluded that: 

Although there is no precise data on ATM crime, violent crime against ATM 

users is relatively rare. Over the decade of the 1990s, ATM crime has actually 

 

35 See Michael S. Scott, Robbery at Automated Teller Machines, U.S. Department of 

Justice, Office of Community Oriented Policing Services, Problem-Specific Guide Series 

No. 8 (2001), at 5 (citing W. Wipprecht, Strike Back at ATM Crime 25 JOURNAL OF 

CALIFORNIA LAW ENFORCEMENT 53 (1991) and R. Wright and S. Decker, ARMED 

ROBBERIES IN ACTION: STICKUPS AND STREET CULTURE (1997)). 
13

decreased from approximately one crime per one million ATM transactions to one 

crime per 3.5 million transactions.36 

In addition, as discussed above, many kinds of crimes often described as ATM crimes 

would not be affected by use of the technology.37 

 2. Distressed Customer Responses 

Critics of emergency-PIN security devices argue that distressed customers are 

unlikely to have the composure to remember and activate their PIN number in reverse 

sequence or activate some other emergency-PIN system, such as the ATMOnGuard 

solution.38 Indeed, with regard to SafetyPIN, some commenters have argued that it is 

 

36 State of Illinois, Office of Banks and Real Estate, ATM Report, available at 

http://www.obre.state.il.us/Agency/news/atmrpt.htm, § I; see also Scott, supra note 35 ̧ at 

2 (internal citations omitted): 

As yet, there are no routinely collected national figures on the incidence of U.S. 

ATM robberies. Estimates are derived from periodic surveys of banks conducted 

by banking associations. According to those surveys, there was an estimated one 

ATM crime (including robbery) per 3.5 million transactions. Statewide surveys 

conducted in California indicated there was one ATM crime per 1.9 million 

transactions in 1986, one per 1.2 million in 1992, and one per 2.5 million in 1995. 

Thus, the California figures suggest that the rate of ATM crime declined by about 

50 percent during that brief period, although we do not know how well the bank 

survey data reflect the actual incidence of ATM crime. Moreover, the surveys 

covered all ATM-related crimes, not just robbery, so the figures overstate robbery 

rates.

The survey figures and findings are still cited as if they reflect current 

conditions, even though it is doubtful that they do. The best one can conclude is 

that the overall rate of ATM related crime is somewhere between one per 1 

million and one per 3.5 million transactions, suggesting that such crime is 

relatively rare. But the figures, without further analysis and some comparative 

context, do not tell us much about the risks of ATM robbery. Local analysis of 

ATM robberies will be necessary to determine how significant the problem is in 

your jurisdiction. 

37 See supra Section II.A. 

38 As discussed below, the type of ATM-associated crime that Mr. Zingher and the seller 

of the ATMOnGuard system emphasize in their marketing efforts is “express 
14

probably challenging for most persons to instantaneously recall and recite their PIN 

backwards (assuming it is not palindromic) at will, much less when they are in physical 

danger.39 For example, Bank of America reported: 

It is unclear that the adoption of an ATM duress device would actually reduce 

crime at the ATM. For example, there are many challenges with the reverse-PIN 

solution. Our customers may have a PIN that is up to 12 digits in length.40 

 

In its investigation of reverse-PIN technology, the Office of Banks and Real 

Estate of the Illinois Department of Financial and Professional Regulation concluded: 

[T]he reverse-PIN system attempts to utilize current technology to provide law 

enforcement with the immediate location and background information concerning 

a potential victim. However, a consumer may be under too much emotional stress 

to properly utilize the system . . . and no evidence exists that the reverse-PIN 

system would actually reduce crime.41 

As such, the Office could only recommend further study into the efficacy of reverse-PIN 

technologies.42 

 

kidnapping,” or a situation in which a criminal abducts a victim, forces him or her (or 

uses his or her card) to make forced withdraws at one or more ATMs, and then 

potentially murders the victim. The concerns raised herein regarding the efficacy of 

ATM emergency-PIN devices would also seem to apply to express kidnappings. 

39 See, e.g., ATM Report, supra note 36, § III: 

[H]uman behavior must be taken into account. Being surprised by the threat of 

bodily harm is extremely stressful. Severe stress such as this impairs the thought 

process. Under these conditions, it is difficult enough for many people to 

remember their correct PIN number. It may be asking too much of a consumer to 

try to remember a second emergency PIN. Criminals will undoubtedly be among 

the first to know of a reverse PIN system and how it works. Any delays or 

glitches incurred by a victim during an ATM crime could cause the criminal to 

physically harm the victim. 

40 Marc Lyons E-mail, supra note 14. 

41 See ATM Report, supra note 36, § I. 

42 Obviously, any assessment of the efficacy of the relevant ATM security technologies 

depends upon how both potential victims and criminals will alter their behavior in 

response to the technologies being made available. The staff is not aware of any studies 

that have carefully considered the behavioral or psychological processes of victims or 

offenders in the presence of such technologies. 
15

3. Law Enforcement Response Times 

Assuming that a distressed customer would be able and willing to activate his or 

her emergency-PIN, such measures would not be expected to deter crime unless they 

actually lead to interruption of the crime in progress, or at least to the identification and 

apprehension of offenders by local law enforcement authorities. A threshold question 

therefore is whether the police could respond quickly enough to a distress call to have a 

reasonable chance of making an arrest, and therefore potentially deter other potential 

criminals from engaging in ATM crimes. If police cannot respond quickly enough to 

interrupt the crime and apprehend the criminals, emergency-PIN systems are unlikely to 

deter ATM-related crime.43 

An offender is unlikely to need to remain at the scene of the crime for very long 

after an ATM customer enters an emergency-PIN. However, DOJ-compiled data in 2006 

indicate that 26.4 percent, or just over one-quarter, of police response times to reported 

robberies occurred within five minutes. Approximately 38.9 percent occurred within 6-

10 minutes, and 15.5 percent occurred within 11 minutes to one hour.44 Thus, in a 

majority of instances, police response times to violent robberies would exceed that 

necessary for interrupting the crime or apprehending the offender.45 Nonetheless, 

responses within 5 minutes were not infrequent. Also, the potential for such a response 

 

43 If police are in fact slow to respond to such distress calls, then ATM users will have 

little incentive to even attempt to use them in the first place, an effect that is exacerbated 

if users recognize that they may “fumble” the attempt and increase their own danger. 

44 Bureau of Justice Statistics, Office of Justice Programs, U.S. Department of Justice, 

Criminal Victimization in the United States, 2006 Statistical Tables (2008), available at 

http://bjs.ojp.usdoj.gov/content/pub/pdf/cvus06.pdf, at tbl. 107. 

45 In addition, Mr. Zingher indicates that his system is expected to provide emergency 

signals to burglar-alarm companies rather than directly to law enforcement, which could 

add to the total response time after the reverse-PIN is used. See Zingher Letter, supra 

note 22. 
16

time could be enough either to deter some crimes or to deter some criminals from 

remaining after obtaining the money to inflict physical injury on their victims. FTC staff 

found no basis for assessing the relative likelihoods of these response times deterring or 

not deterring crimes or physical injury. 

Furthermore, some ATM crime victims never actually see their offender because 

they are approached from behind. Even if the police can get to the scene relatively 

quickly, victims may be able to provide the authorities only limited information about the 

physical characteristics of the offender. 

 4. Potential Changes in Offenders’ Practices 

 To the extent that the presence of an emergency-PIN system at an ATM may deter 

robberies at that ATM, another issue is whether voluntary, localized installation of such a 

system would simply cause offenders to frequent other ATMs without the system. 

Further, even deployment of such systems at all ATMs in a relatively wide geographic 

region, such as in response to a legal mandate, might not have a significant impact on the 

incidence of ATM crimes. Such laws may limit the extent to which potential criminals 

may geographically displace their activities, but they might do little to mitigate any 

temporal displacement effects. For example, the installation of emergency-PIN systems 

at ATMs throughout a large metropolitan area may result in criminals adjusting their 

behaviors so as to confront the ATM customer only after he or she has already withdrawn 

funds.46 Such adjustments in criminal behaviors, which seem relatively minor, could 

result in little or no decrease in the frequency of ATM crimes, though the latter 

 

46 This discussion assumes that potential criminals would be deterred in the first instance 

from confronting victims in the process of attempting to withdraw funds at ATMs with 

emergency-PIN systems, but, for the reasons discussed above, this assumption may not 

hold. See supra Section III.B.2. 
17

adjustment could cause the average per offense amount of money stolen from the victim 

to fall. 

 The marketers of emergency-PIN technologies have focused on a subset of ATM 

crimes known as “express kidnappings” (also referred to as “forced withdrawals”).47 

These crimes involve an offender abducting a victim, taking him or her to an ATM (or 

approaching the victim while he or she is in the process of withdrawing money), and 

having the victim withdraw funds from their bank account (by either coercing the victim 

to enter his or her PIN or by revealing the PIN to the criminal). The criminal may then 

forcibly take the victim to other ATM locations in order to force the withdrawal of more 

funds from the victim’s account. By definition, these crimes necessarily involve the 

offense taking place before or during the time the victim is using the ATM, and as such, 

potential temporal displacement effects may not apply. But again, whether distressed 

customers would be able or even willing to use emergency-PINs under express 

kidnapping scenarios is unclear, and the issue of police response times still applies in 

these cases.48 

 

47See Zingher Letter, supra note 22; http://www.atmonguard.com/about/index.htm. 

48 Furthermore, some academic research suggests that it may be possible for criminals to 

partially “defeat” an emergency-PIN system even in the context of forced ATM 

withdraws – particularly those that rely on a “two-password scheme” such as SafetyPIN 

and ATMOnGuard – through so-called “forced randomization attacks.” See, e.g., Jeremy 

Clark & Urs Hengartner, Panic Passwords: Authenticating under Duress 6 (unpublished 

manuscript, available at http://www.cs.uwaterloo.ca/~j5clark/papers/panic.pdf). This 

possibility arises because criminals may become aware of the specific characteristics of 

the emergency-PIN mechanism put in place, and accordingly, adjust their behavior so as 

to decrease any possibility of being apprehended as the result of an ATM user activating 

an emergency-PIN. 
18

C. Costs of Use 

The use of an emergency-PIN system might increase physical danger to the victim 

due to the difficulties distressed customers may experience in using the system. The 

banks responding to staff’s inquiries stated the belief that the real risk of customers 

fumbling to put in their PIN in reverse would result in a greater likelihood of personal 

harm befalling the customer if the perpetrator perceives the ATM customer as attempting 

to stall. In discussing the difficulties of using such a system, as described earlier, Bank of 

America stated: “There are also concerns that customers under stress may be unlikely to 

remember the reverse of their PIN, which may place them in greater danger should the 

perpetrator figure out what they are attempting to do and escalate the situation.”49 Wells 

Fargo concurred: “A customer under duress might have a difficult time remembering 

their alarm [emergency-] PIN . . . . A customer who is [contemplating] sounding an alarm 

[by activating their emergency-PIN] might try to unsafely delay a perpetrator in the hopes 

that police will quickly respond; this could worsen an already unsafe situation.”50 

 

49 Marc Lyons E-mail, supra note 14. 

50 Letter from Jonathan Velline, Senior Vice President, ATM and Store Strategy, Wells 

Fargo to FTC staff (October 16, 2009) (Wells Fargo Letter). Wells Fargo goes on to 

note: 

Finally, none of these solutions prevent crime. If a crime is being committed, we 

believe the safest course of action is for a customer to comply with the demands 

of their attacker. The majority of Wells Fargo ATMs are equipped with 

surveillance cameras. Surveillance tapes can be examined to retrieve information 

and help law enforcement officials identify thieves. Wells Fargo customers are 

not liable for unauthorized ATM transactions when they use their Wells Fargo 

ATM debit card. 

Id. (emphasis added). On the other hand, a critical limitation of security cameras is that 

offenders can simply disguise their appearance while committing offenses (e.g., wearing 

a mask or hood), which makes identifying and subsequently apprehending the offender 

inherently more difficult. 
19

Diebold Inc., a manufacturer of ATMs and provider of various ATM security 

solutions,51 indicated that it has had numerous conversations with banking institutions 

regarding the implementation of an emergency- or reverse-PIN system.52 None of those 

banks expressed any interest due to concerns that customers might increase their chances 

of harm if they fumbled entering their emergency-PIN numbers.53 Diebold concurs with 

this sentiment and does not believe that implementing an emergency-PIN system is 

prudent.54 

The report of the Illinois Office of Bank and Real Estate similarly notes: 

The deterrent [effect] of having such a system in place is another touted feature of 

the [reverse PIN] system. However, deterrence does not prevent crime in 

progress. More importantly, the law enforcement community does not generally 

encourage resistance or confrontation to thwart theft or robbery. The risk of 

physical harm to the customer is greatly increased should they resist. When 

coupled with the fact that ATMs generally limit withdrawals to approximately 

$200.00, engaging a criminal in an altercation or otherwise offering resistance 

over such an amount does not appear to be prudent.55 

 

51 See http://www.diebold.com/solutions/atms/opteva/html/default.htm. 

52 Stewart Interview, supra note 29. See also 

http://www.diebold.com/atmsecurity/securityupdate.htm. 

53 Stewart Interview, supra note 29.

54 Id. 

55 ATM Report, supra note 36, § III. In addition to the increased risk of physical harm, 

there is some possibility that ATM users might occasionally confuse their regular and 

emergency-PIN, thereby unintentionally setting off the duress signal and causing law 

enforcement to incur the costs associated with false alarms. For a discussion of the 

prevalence of false alarms in the context of duress or hostage codes used for home 

burglar alarm systems see http://www.faraonline.org/DuressResolution.pdf (“Alarm 

system users can easily get their Duress Code confused with their regular code. When 

the Duress Code is entered, the user believes he has turned the system off, not aware that 

armed law enforcement personnel may be responding to the signal in an escalated 

emergency mode. This creates an undesirable, dangerous situation for both the alarm 

user and the law enforcement personnel.”)
20

FTC staff found no evidence confirming this risk (note again that the technologies have 

never been employed), but staff also found neither evidence nor analysis disputing the 

risk. 

D. Costs of Implementation 

FTC staff could not reliably determine the costs of implementing an emergencyPIN technology, in part because such a technology has not been adopted for any ATM. 

Respondent banks, an ATM security firm, and a major provider of electronic payments 

software all reported that they have not developed any formal cost estimates of deploying 

and maintaining the technology.56 One cost estimate offered by a potential supplier of 

the available technology is not based on any formal cost study. Further, potential 

purchasers of the technology, the potential supplier, and third parties define the cost 

components differently. The discussion below sets out the information and analysis of 

costs that FTC staff was able to identify. 

 1. Bank Cost Estimates 

Bank of America provided FTC staff with a descriptive listing of the types of 

costs it believes would be incurred in implementing a reverse-PIN technology.57 Bank of 

America maintains that software upgrades likely would be needed for individual ATMs 

 

56 For instance, Wells Fargo stated: “We have not estimated these costs, since we don’t 

think the solutions are feasible.” Wells Fargo Letter, supra note 50. Similarly, Citibank 

responded: “This [i.e., a cost estimate for implementing emergency PIN or alarm button 

technologies] has not been studied and the information on cost is not available at this 

time.” E-mail from Glen Mellone, Vice President, Citibank Security and Investigative 

Services to FTC staff (November 9, 2009). 

57 See E-mail from Marc Lyons, Bank of America, to FTC staff (October 9, 2009) (Marc 

Lyons E-mail II). Bank of America was unable to provide to the staff any dollar 

estimates of the various cost elements they identified pertaining to an emergency-PIN 

technology. 
21

as well as for the central systems that run the ATM networks.58 Other costs relate to: (1) 

additional investments in physical capital (e.g., installing a dedicated high-speed data 

transmission line between the ATM and the emergency dispatch center); (2) ongoing 

maintenance costs for the software and physical equipment and other recurring costs; and 

(3) licensing fees/royalties for the patented emergency-PIN system.59 

Upgrades for the central systems might be needed to ensure interconnectability 

among all ATMs, regardless of network. For example, if a Bank of America account 

holder is held up while attempting to withdraw funds from a Citibank ATM, the Citibank 

ATM would have to be able to recognize the emergency-PIN associated with a Bank of 

America debit card in order to properly alert the local authorities. Wells Fargo noted: 

“For an alert mechanism to be effective, it would need to be consistently applied 

regardless of the ATM that was used (owned by the customer’s bank, another bank, or an 

independent operator, the card that was used, and the municipality in which the crime 

took place). This would require the coordination of literally thousands of [different] 

entities.”60 However, the respondent banks were unable to provide information on the 

extent to which the system would require integration greater than the currently existing 

systems, or any cost estimates to achieve such greater integration. 

 

58 Id. 

59 Id. Bank of America notes the costs of royalty payments as “unknown.” Id. 

60 Wells Fargo Letter, supra note 50; see also Marc Lyons E-mail, supra note 14 

(“Operational challenges also exist if another bank’s cardholder is using our ATM . . . . 

The ATM networks currently do not possess the technology to verify the cardholder’s 

reverse PIN and pass that message over the network to the ATM owner/operator, along 

with the additional message to call the police.”). 
22

2. Potential Suppliers’ Cost Estimates 

The potential supplier of an available emergency-PIN system, Mr. Zingher, states 

that installing his SafetyPIN solution would cost approximately $25 per ATM.61 This 

figure is his estimate of the cost, expressed on a per-ATM basis, to upgrade the PIN 

verification subroutine on the various computers that run the nation’s ATM networks to 

enable them to send out an electronic text message to the relevant alarm center.62 Mr. 

Zingher’s estimate implies that the total cost of upgrading the approximately 400,000 

ATMs deployed across the U.S.63 to use his emergency-PIN technology would be around 

$10 million. 

Mr. Zingher states that his system does not require software or other upgrades to 

the individual ATM machines. It is not clear whether Mr. Zingher’s estimate reflects 

interconnection costs among the ATM networks that might be needed to implement an 

emergency-PIN system across the country. In particular, one of the features marketed 

with SafetyPIN is its ability to pull information from the distressed customer’s driver’s 

license record. This information is pulled at the time the distressed customer activates 

the technology, and it is relayed to law enforcement officers along with the electronic 

message indicating the customer’s location. Making driver’s license data available to the 

police may allow them to identify a victim who is transported during an express 

 

61 See, e.g., Final Report of the ATM Safety Study Committee, Senate Research Office, 

Georgia General Assembly (2006), at 6, available at 

http://www.legis.state.ga.us/legis/2009_10/senate/publications/sro/committee_reports/20

06/atm-safety-study-committee-report.pdf. 

62 Zingher Interview, supra note 16; Zingher Letter, supra note 22. 

63 The estimated number of ATMs in the U.S. is taken from the Final Report, supra note 

61, at 3; Zingher Interview, supra note 16. 
23

kidnapping scenario. Furthermore, having access to this information may prevent law 

enforcement from potentially mistaking the victim for the offender.64 As such, SafetyPIN 

would require interconnection with state government drivers’ license computers and 

databases both within and across states, and possibly even internationally. It is not clear 

whether Mr. Zingher’s cost estimate reflects the initial and recurring expenses associated 

with establishing these particular interconnection routes. 

Mr. Zingher’s estimate assumes that there is already a form of emergency-PIN 

system in place on the ATMs.65 Mr. Zingher provided no details about the proportion of 

the estimated 400,000 ATMs in the U.S. that possess this type of alarm system, and FTC 

staff do not possess sufficient information to assess this claim. 

Mr. Zingher’s analysis presumes that the alarm sent by the emergency-PIN 

system would be received by a burglar alarm company, rather than directly by law 

enforcement. The estimate does not include any new expenditure by law enforcement to 

receive electronic messages directly. 

 

64 See Zingher Patent, supra note 20; Zingher Letter, supra note 22; ATM Report, supra 

note 36 § III (“In addition to the location of the ATM, police could find out who the 

customer was with information taken from the customer’s bank account records. Police 

could also access a description of the customer from the Secretary of State’s Drivers’ 

Services Division. By the time police reach the ATM they would know who the 

customer is, what s/he looks like, and where s/he lives.”). 

65 Mr. Zingher stated: 

One of the reasons that the cost of installing the completed system is so low is that 

[there is] already an emergency PIN system in place on the ATM. It is for the 

benefit of the employee who loads the cash into the ATM. The message routing 

is already available at the burglar alarm company that monitors the ATM. The 

burglar alarm company just gets the alert from my system instead of the keypad 

the worker uses. 

E-mail from Joseph Zingher to FTC staff (December 3, 2009). 
24

The estimate apparently does not include licensing and royalty costs. Mr. Zingher 

stated: “The licensing costs, the royalties paid to the patent owners are really 

imponderable. Whatever the market will bear is the only reasonable thing to say.”66 Mr. 

Zingher’s estimate also apparently does not include maintenance costs for the software or 

physical equipment, or any added staff costs. 

 The seller of the ATMOnGuard system was unable to provide the staff with a cost 

estimate of deploying their technology at ATMs.67 The seller is currently attempting to 

arrange a series of trials for the deployment of their system with various banks – which 

could inform a cost estimate – but so far no such trial has been initiated.68

 3. Third-Party Cost Estimates 

 Diebold, Inc., which manufactures ATMs and ATM security systems, stated that 

the implementation of an emergency-PIN system is technically feasible and would not 

likely require any changes (physically or otherwise) to the individual ATMs 

themselves.69 The company indicated that any software modifications needed to 

implement an emergency-PIN system would occur at the “host end,” specifically, at the 

software that runs the host security module (“HSM”), which is a hardware component.70 

The function of the HSM is to run the PIN verification system, which includes decrypting 

 

66 Zingher Letter, supra note 22. 

67 Russikoff Interview, supra note 17. 

68 Id. 

69 Stewart Interview, supra note 29. 

70 Id.
25

PINs sent over the ATM network and making the requisite PIN “comparisons” (i.e., 

verifying that the PIN entered by the customer is the correct one).71 

Diebold stated that modifying the HSM software to implement the reverse-PIN 

version of an emergency-PIN system “would be complex” and that the modifications 

might affect transaction processing speeds (but not to an extent that would noticeably 

affect the speed at which a withdrawal was made as compared to a regular PIN).72 

According to the company, the HSM software would have to be modified in order to 

handle a larger number of PINs requiring processing under a reverse-PIN system, while 

also conducting more PIN verifications. Diebold indicated that the modifications would 

likely be in the thousands of dollars per machine but was unable to provide a precise cost 

estimate to modify the HSM software to implement a reverse-PIN system.73 Finally, 

Diebold indicated that some additional expenses probably would have to be incurred by 

banks in order to process duress messages sent out by a customer activating a reversePIN,74 such as additional employees to handle the communications between the alarm 

dispatch center and any other relevant entities. Diebold stated that it generally agrees 

with financial institutions regarding the costs that banks would have to incur in order to 

modify the ATM backbone network (as opposed to costs of reconfiguring individual 

ATMs themselves) in order to implement a reverse-PIN system.75 

 

71 Id. 

72 Id. 

73 Id. 

74 Id. 

75 Id. 
26

 ACI Worldwide, a major provider of electronic payments software, including the 

software that runs the HSM,76 stated that it had once started the process of conducting a 

formal cost study for implementing a reverse-PIN system in Illinois when the State 

considered requiring the system on ATMs.77 The company never completed the cost 

study because the requirement was never enacted.78 Hence, it could not provide FTC 

staff with any cost estimates. ACI Worldwide stated that an emergency-PIN system 

likely could be implemented solely through software modifications to the ATM network, 

but was uncertain if such modifications would be limited only to the software pertaining 

to the HSM.79 

 The State of Illinois ATM Report noted four significant “computer interface 

barriers” to an effective reverse-PIN system:80 

 First, are the limitations inherent in the use of PIN numbers. The system 

would double the amount of PINs used per person.81

 Second, conversion to this system requires a significant commitment in 

resources to writing the new computer programs that recognize the 

reverse-PIN and then make multiple complex decisions. Currently, ATMs 

communicate with banks and make what are termed ‘binary’ (i.e., simple 

‘yes/no’) decisions concerning the account and transaction information. 

Under the reverse-PIN system, the main computer must: (a) determine and 

communicate with the police station closest to the ATM; (b) the computer 

must communicate with the bank account of the cardholder and obtain 

account information that is usually confidential and protected (this process 

 

76 Interview with Richard A. Duval, Senior Strategic Alliance Manager, ACI Worldwide 

(March 3, 2010). 

77 Id.; see supra notes 31-32 and accompanying text for discussion on the history of 

reverse-PIN legislation in Illinois.

78 Duval Interview, supra note 76. 

79 Id. 

80 See ATM Report, supra note 36, § III (“Computer interface problems are estimated to 

be significant and costly in implementing the reverse PIN system at this time.”). 

81 Id. 
27

is more complicated if the ATM is not from the accountholder’s bank); 

and, (c) the main computer must then also communicate with the Secretary 

of State’s office for driver license information.82

 Third, most law enforcement agencies do not have the computer capacity 

to provide the necessary real time communication with an ATM. Many 

police 911 units respond only to voice communication, although some are 

now taking calls via the internet. In addition, there is no assurance of 

immediate response by police agencies. This may result from the huge 

number of calls handled in urban areas to the geographic separation that 

occurs in rural locations.83

 Fourth, the cost to reconfigure the ATM system, including shared ATM 

networks, can be quite high . . . . The physical reconfigurations needed to 

make changes to machines have been estimated at $1,500.00 to the 

thousands of dollars each. The minimum impact is estimated to be at least 

$7,500,000.00 [for ATMs regulated by the Illinois Office of Banks and 

Real Estate]. This does not include the software programming costs. This 

estimate does not include the additional costs associated with thousands of 

ATMs in Illinois that are not regulated by the Office of Banks and Real 

Estate. To be fully functional, the [emergency-PIN] system would have to 

have communication capabilities with financial institutions worldwide in 

order obtain customer account information. The system would likewise 

have to communicate with driver license agencies or similar authorities 

worldwide to obtain descriptive information about the victim.84

These barriers led the Illinois Office of Banks and Real Estate to conclude that 

“significant barriers exist in the application of reverse-PIN systems at this time.”85

 Staff also contacted two ATM-industry trade associations, the ATM Industry 

Association and the Electronic Funds Transfer Association,86 to determine if they had any 

 

82 Id. Communication with the office for driver’s license information is required in order 

to provide the responding police officer(s) with a physical description of the distressed 

ATM customer, including a driver’s license photo. 

83 Id.

84 Id. The report does not provide any further information regarding the source of the 

cost estimates cited therein. 

85 Id. Mr. Zingher refutes the Illinois conclusion that implementing a reverse PIN 

solution would require any physical reconfiguration of individual ATM machines. 

Zingher Letter, supra note 22. 

86 See http://www.atmia.com/ and http://www.efta.org/, respectively. 
28

relevant data concerning the costs of deploying an emergency-PIN system. Neither of 

these entities was able to provide such information.87

E. Summary 

 Based on the above information and analyses, staff concludes that the costs of 

implementing an emergency-PIN system could be substantial, though it cannot gauge 

how substantial. Staff also concludes that there is currently no way to determine the 

extent of ATM-related crime subject to interruption or deterrence through such a system 

or the net effect of deploying such a system. While there may be some potential for 

decreasing ATM-related crime and injury, there is also the possibility that emergencyPIN systems will have little or no effect, or that they will even increase injury (although 

to what extent is not certain). The anecdotal evidence that the staff relied upon does not 

allow for any definitive conclusions regarding the efficacy of the reviewed emergencyPIN systems to affect ATM crimes. 

IV. Alarm Button Technology 

 A. Description and Use 

FTC staff identified a single manufacturer of an ATM user alarm button 

technology, SafeAlert Systems, which sells its patented “ATM911 Emergency 

Communications System” (hereafter “ATM911”). According to the company: 

[ATM911] works similar to a programmable speaker telephone. When someone 

using an ATM feels that they have an emergency situation, they will push the 911 

button. Within moments, the local 911 dispatcher answers the call and can be 

heard at the ATM unit. The 911 dispatcher will not only be able to hear the 

 

87 E-mail from Michael Lee, Chief Executive Officer, ATM Industry Association to FTC 

staff (March 3, 2010); Interview with Dennis Ambach, Chairman, Legislative and 

Regulatory Council, Electronic Funds Transfer Association (March 4, 2010). 
29

caller, but he/she can also hear noises and conversations within twenty (20) feet of 

the ATM.88 

ATM911 can be installed on either walk-up or drive-up ATMs89 and does not require the 

customer to purchase a new ATM.90 

 SafeAlert Systems has sold alarm button systems for about 2,000 individual 

ATMs over the past 18 years.91 If all these buttons were currently in use, that would 

represent approximately 0.5 percent of all ATMs in the U.S., assuming there are 400,000 

ATMs in the U.S.92 The company reported that some banks have chosen to uninstall the 

buttons, and for this reason it cannot provide an exact figure on the number of ATMs at 

which ATM911 is currently deployed. Furthermore, because the company no longer 

installs the systems itself, but instead works through third party “dealers” (often security 

system companies) who perform this function, it is unable to provide the number of bank 

entities that have purchased (or are currently using) the system.93 

None of the ATMs of the respondent banks currently employ alarm button 

technology. One of the respondent banks, Wells Fargo, reported conducting a pilot 

program in the early 1990s with such alarm buttons on several ATMs in California. 

According to that bank, this program resulted in a large number of false alarms that led 

law enforcement officials to request the removal of the devices.94

 

88 http://www.safealert.com/How.shtml. 

89 http://www.safealert.com/ProductDescription.shtml. 

90 Interview with Larry Steelman, Vice President, SafeAlert Systems (February 25, 

2009). 

91 Id. 

92 See supra note 63. 

93 Steelman Interview, supra note 90. 

94 Wells Fargo Letter, supra note 50. 
30

 Several small cities have mandated the installation of alarm buttons along with 

surveillance cameras on all ATMs that operate within their jurisdictions. SafeAlert 

Systems informed FTC staff of three cities outside Cleveland, Ohio, that do so: 

Broadview Heights, Brooklyn, and Strongsville.95 FTC staff also identified another small 

municipality that has mandated the adoption of ATM alarm buttons, the Sharon Hill 

Borough in Delaware County, Pennsylvania. The Borough’s ordinance, which was 

passed in March 2006, required that alarm buttons and CCTV cameras be installed on all 

outdoor ATMs.96 Only one of the ATMs in the Sharon Hill Borough is located outdoors, 

and it has an alarm button.97

 SafeAlert Systems does not recommend that a distressed ATM user attempt to 

push the alarm button while a crime is in progress, as doing so could increase the 

probability that the offender will inflict physical harm.98 Rather, SafeAlert Systems 

advises victimized ATM users to push the button in order to request assistance or to 

report the crime only after the offender has left the scene. ATM911 is not a technology 

specifically designed to enable a consumer that is under duress to electronically alert a 

local law enforcement agency that an incident is taking place, and thus is not a system 

that the Act mandates that the FTC study. 

 

95 See City of Broadview Heights, Ordinance No. 93-96 (approved July 23, 1996); City of 

Brooklyn, Ohio, Ordinance No. 1996-7 (adopted February 2, 1996); City of Strongsville, 

Ohio, Ordinance No. 1996-123 (approved July 1, 1996). 

96 Interview with Chief Robert Tinsley, Borough of Sharon Hill Police Department 

(March 2, 2010). 

97 Id. 

98 Steelman Interview, supra note 90; see also Final Report, supra note 61, at 6. 
31

 B. Likelihood of Decreasing ATM-Related Crime or Injury 

As with emergency-PIN technology, alarm button systems do not address most 

kinds of ATM-related crimes, and existing data on ATM crimes do not distinguish 

between those that might have been halted or solved through use of an alarm button and 

those that would not. Further, as with emergency-PIN technologies, it is not clear 

whether police response times are fast enough to create a reasonable probability that law 

enforcement officers will be able interrupt the crime or make an arrest. 

Wells Fargo described an alarm button pilot program it had conducted, which 

showed no positive effect over its duration: 

In the early 1990s Wells Fargo conducted a pilot with the Oakland, California 

Police Department to install emergency “911” alarm buttons on several Wells 

Fargo ATMs in Oakland. These alarms were installed at the request of the Police 

Department based on concerns of crime occurring in the vicinity of the ATM. 

The experiment lasted less than six months and was removed at the request of the 

Police Department based on a deluge of false alarms. Out of the 500 alarms we 

had during the pilot program not one was legitimate or found to have merit.99

The Sharon Hill Borough ordinance was prompted by a murder at the only 

outdoor ATM location; however, the crime in question did not actually involve an ATMrelated offense but rather a confrontation between two men that just happened to occur at 

the location.100 The Borough could not identify any incident where a dispatch resulting 

from the activation of the alarm button actually involved a crime.101

While SafeAlert Systems recommends against pressing an alarm button during an 

incident, it claims that the mere presence of the button may serve as a deterrent to prevent 

ATM crimes from being committed in the first place at those machines where the system 

 

99 Wells Fargo Letter, supra note 50. 

100 Tinsley Interview, supra note 96. 

101 Id. 
32

is installed.102 However, it was not aware of any formal studies that have evaluated the 

effect of the technology on crime.103

 SafeAlert Systems provided FTC staff with letters supporting the adoption of 

ATM911 from officials of two of the Ohio cities. A letter from an official for the City of 

Brooklyn official stated that ATM911 “was enacted . . . for the purpose of protecting the 

users at [ATMs] in the City of Brooklyn . . . . Our City’s Chief of Police . . . feels that 

having these panic buttons are a great deterrent in fighting crime at [ATMs].”104 This 

letter does not provide any data or indication on the extent to which ATM crime rates 

may have fallen as a result of ATM911 adoption. A letter from the Strongsville Police 

Department speaks to the issue of deterrence more directly, stating: “Before this 

ordinance was enacted there were two robberies at bank ATMs within Strongsville. After 

the ordinance there have been no more robberies.”105 

 Despite these two testimonials, however, the effect of the alarm button on ATM 

crime is unclear. First, as the City of Strongsville letter indicates, there were only two 

ATM crime incidents preceding the adoption of the ordinance. It would be inappropriate 

to infer any causal crime-reducing effects from deployment of the ATM911 system from 

such a small a number of events. Second, each city’s ordinance mandated installation of 

the ATM911 system concurrently with closed-circuit television (“CCTV”) cameras on all 

 

102 http://www.safealert.com/How.shtml. 

103 Steelman Interview, supra note 90. SafeAlert Systems indicated that one reason why 

no such studies have been conducted is because there are no reliable data on ATM 

crimes. Id. 

104 Letter from Kenneth E. Patton, Mayor, City of Brooklyn to New Jersey Assemblyman 

Neil Cohen (August 2004). 

105 Letter from Sergeant John Hall, Crime Prevention Specialist, Strongsville Police 

Department to Richard Aborn, The Camber Group (April 30, 1999). 
33

ATMs. It is unclear that any deterrent effect stemming from the adoption of the ATM911 

system could be determined separately from any deterrent effect effectuated by the 

installation of CCTV cameras at all ATMs that occurred at the same time.106 

 Third, as SafeAlert acknowledged, even if crimes are deterred at those locations 

where a visible alarm button is installed, criminals may simply respond by searching out 

and committing crimes at ATMs that do not have the button present.107 To the extent that 

criminals simply “geographically displace” the locations at which they commit their 

crimes in response to the deployment of ATM security technologies at specific sites, 

overall ATM crime rates may not be substantively affected.108 In addition, widespread 

deployment of alarm button systems at all ATMs over a broad geographic area could 

result in “temporal displacement,”109 where a criminal approaches an ATM customer 

after the withdrawal is complete and the customer is no longer close enough to the ATM 

to press a button. It is not clear to what extent criminals may have adjusted their behavior 

in such ways.110 Because police reports and records may not detail the fact that a robbery 

 

106 The City of Strongsville ordinance also mandated specific lighting levels around 

ATMs, see id., which further obfuscates any potential determination of the deterrent 

effect that might pertain specifically to the adoption of the ATM911 system. 

107 Steelman Interview, supra note 90. 

108 A 1993 study conducted by the Chicago Police Department concluded that overall 

crime rates would likely not be affected by ATM security devices, such as panic buttons, 

because they “would likely just result in the movement of crime to different locations 

where victims are more susceptible.” See ATM Report, supra note 36, § IV. 

109 See supra Section III.B.4. 

110 It is also unknown to what extent any observed decrease in ATM crimes following the 

introduction of alarm buttons might simply reflect changes in the behaviors of law 

enforcement or ATM customers. Police may respond to an ATM crime by increasing 

their monitoring of ATM locations or by patrolling the areas surrounding ATMs more 

frequently at the same time alarm buttons are installed. Any reduction in ATM crimes 

may stem from the increased police presence rather than from the installation of alarm 

buttons per se, but it is difficult to separate their respective effects given the available 
34

took place at or in the vicinity of an ATM, a reported ATM robbery in an area with alarm 

buttons may get officially recorded as an “ordinary” robbery rather than as an ATM 

robbery. 

An assessment of the likelihood of actual reduction in crime or injury should take 

into account customers’ abilities to activate the system and the results of activation.111 

While an alarm button system does not create the kind of difficulty for a distressed victim 

to remember an altered PIN number under duress, an alarm button’s use is not invisible to 

the robber, who may be able simply to prevent the victim from pressing the button 

through threats or force. In addition, the potential effects of law enforcement response 

times may be varied and the available information provides no basis for gauging their 

relative likelihood.112 

 C. Costs of Use 

 1. Increased Physical Danger 

As with emergency-PIN use, attempts to use an alarm button during a robbery 

might increase the risk of physical danger to the customer; this risk may be higher for 

alarm buttons as the buttons are highly visible and it is unlikely that customers can press 

them without offenders knowing. As discussed earlier, law enforcement generally 

 

data. Similarly, in the wake of an ATM crime ATM users may either avoid using those 

ATMs at which an offense took place or change the manner in which they use ATMs 

(e.g., only withdrawing money during the day when a large number of persons are 

present, not using ATMs as frequently, only withdrawing cash at supermarkets or at 

ATMs located inside buildings). If such changes in ATM user behavior are correlated 

with the deployment of alarm buttons, there is a risk of incorrectly attributing any 

observed reduction in ATM crime as stemming from the deployment of the alarm buttons 

themselves. 

111 See supra Section III.B.2. 

112 See supra Section III.B.1.
35

discourages efforts to resist robberies due to heightened risk of physical injury, and the 

manufacturer of the alarm button system, SafeAlert, itself cautions that the button should 

not be pressed during a robbery or until the offender has left the scene. Yet the visible 

presence of the button may encourage a distressed customer to press it as soon as 

possible, thus incurring that additional risk of harm. 

 2. False Alarms 

False alarms are an unintended consequence associated with alarm button 

technologies. Banks cite the frequent occurrence of so-called “false alarms” as one of the 

major shortcomings associated with these devices. Wells Fargo’s alarm button pilot 

program produced 500 false alarms and no legitimate ones.113 Wells Fargo did not 

provide further detail on the circumstances underlying the 500 false alarm instances, but 

they may have included accidental pressing of the button, pranks, and overly nervous 

ATM patrons who believed they were under threat but actually were not. If police must 

routinely respond to these false alarms, fewer resources will be available for deterring or 

solving real crimes, which is another potential cost of alarm button technology. 

 SafeAlert Systems was the supplier of the alarm button devices used in the Wells 

Fargo pilot program.114 The company claimed that Wells Fargo would not share specific 

information regarding the nature of the false alarms after the pilot program was 

terminated.115 Although SafeAlert Systems subsequently modified the ATM911 system 

so that the alarm button could only be activated by the insertion of an ATM customer’s 

card, Wells Fargo was not interested in readopting the technology. The card-activation 

 

113 Wells Fargo Letter, supra note 50. 

114 Steelman Interview, supra note 90. 

115 Id. 
36

feature is now standard on the ATM911 system, and SafeAlert Systems claimed it has 

greatly reduced the incidence of false alarms.116 

 The experience of Sharon Hill Borough, which mandated an alarm button system 

at outdoor ATMs, is that most activations of the alarm button have arisen from ATM 

customers who believe that pushing the button will call a customer service agent or a 

teller inside the adjoining bank, e.g., to request assistance in operating the ATM.117 The 

Borough could not identify any incident where a dispatch resulting from the activation of 

the alarm button actually involved a crime.118

D. Costs of Implementation 

 SafeAlert Systems reported that the cost of implementing its ATM911 system on 

an ATM, including the costs of installation charged by the dealer, is approximately 

$1,500.119 SafeAlert Systems does not charge the users of its ATM911 system any 

licensing fees or royalties.120 The company stated that ongoing maintenance costs were 

to be expected; it was unable to provide an estimate on these costs but expected them to 

be relatively small.121 

 

116 Id. 

117 Tinsley Interview, supra note 96. 

118 Id. 

119 Steelman Interview, supra note 90. SafeAlert Systems also offers an option (for an 

additional charge) that allows up to three ATMs (e.g., one drive-up and two walk-up 

ATMs) to operate from a single ATM911 system. Id.; see also

http://www.safealert.com/about.shtml for descriptions of other options for the ATM911 

system. 

120 Steelman Interview, supra note 90. 

121 Id. SafeAlert Systems emphasizes that ATM911 does not require the installation of an 

additional phone line. Rather, the system can operate on a fax line already connected to 

the ATM. When the alarm button is pushed, the system “will automatically seize use of 

the telephone line and call 911. All calls on the system are made directly to the 911 
37

Bank of America identified as a cost of an alarm button system “additional FTE 

[full-time employees] required to support communications to [a] security command 

center to provide law enforcement with specific details regarding incidents specific [to] 

ATMs.”122 It is not clear, however, whether Bank of America was basing its cost 

assessment on the system offered specifically by SafeAlert, which simply activates a call 

channel for operator listening, and would not likely require the deployment of additional 

bank employees. 

V. Conclusion 

FTC staff’s investigation revealed that requisite data to evaluate the efficacy of 

ATM emergency-PIN and alarm button technologies are not available. The best 

available qualitative information – obtained from staff’s review of past government 

investigations into ATM emergency-PIN technologies and responses received from trade 

associations, banks, patent holders, and others regarding the relative costs and benefits of 

these devices – suggests that these technologies: (1) may not deter any type of ATM 

crime, and in some instances may actually increase the risk of danger to ATM customers; 

(2) might entail banks incurring non-trivial costs for their deployment; and (3) could 

result in at least some false activations that might lead to the inefficient allocation of 

police resources. The information obtained by staff does not allow the staff to obtain an 

estimate of the costs of implementing emergency-PIN or alarm button technologies, nor 

 

Dispatcher. There is no need for a monthly monitoring charge!” See

http://www.safealert.com/ProductDescription.shtml. 

122 See Marc Lyons E-mail II, supra note 57 (wherein Bank of America also notes that the 

installation of ATM alarm buttons would involve the “cost associated with purchase [and 

installation] of physical alarm devices at each of 18,000 [Bank of America] ATMs”). 
38

does anecdotal evidence reviewed by FTC staff allow for any definitive conclusions 

about whether the reviewed emergency-PIN or alarm button systems reduce ATM 

crimes.