BANK ON COALITION PLAYBOOK Equipping Bank On coalitions for local banking access success.
Last Updated: May 2017
Table of Contents
Chapter 1: Bank On Guiding Principles
Chapter 2: National Account Standards (2017-2018)
Chapter 3: B ank On Coalition Financial Institution Partnerships: Statement of Principles
Chapter 4: B ank On National Account Standards Validation and Certification: Frequently Asked Questions
Chapter 5: T alking Among Ourselves: The Bank On Listserv
Stay tuned for the next Chapter!
Last Updated: May 2017
Dear Bank On ColleaguesAcross the country and for the last several years, Bank On coalitions have taken similar, but diverse local approaches to boosting banking access for the millions of people still outside of the financial mainstream. Local Bank On coalitions generally share two key characteristics: they believe that banking access is critical to individual and community financial security, and they know that real progress takes a joint effort among stakeholders and partners committed to the cause. Along the way, the field has produced best practices and hard lessons learned, both. With the advent of a national platform, the Cities for Financial Empowerment Fund now provides tools, funding, and technical assistance to support local coalition success. These tools include producing the Bank On National Account Standards, capacity grants, research pilots, and now this Bank On Coalition Playbook. This Playbook includes tools and best practices gathered through both local experience and national experts, from advocates and financial institutions, from regulators and community organizations. As the CFE Fund continues to release new chapters to this living and breathing resource, we encourage you to share your ideas, experiences, and needs to help ensure that the Playbook can advance our joint and individual efforts. Thank you! The Cities for Financial Empowerment Fund
Bank On Guiding Principles
Bank On’s goal is to ensure that everyone has access to safe and affordable financial products and services. Bank On coalitions are local partnerships between municipal officials; city, state, and federal government agencies; financial institutions; and community organizations that work to improve the financial stability of unbanked and underbanked residents in their communities. The Cities for Financial Empowerment Fund (CFE Fund) leads a national movement that supports local coalition efforts to expand banking access for consumers outside the financial mainstream, including through municipal infrastructure. Below are guiding principles for the Bank On movement.
Consumers Should Have Access to Mainstream Banking Accounts • Consumers should not be forced to rely on expensive alternative financial services. • Banking access starts with a basic transaction account, which is the first rung of a financial capability ladder that builds over time to include savings, secured credit, and unsecured loans. Financial Institutions Should Provide Accounts that Meet the Bank On National Account Standards • The National Account Standards outlines the core functionality of a safe and appropriate account. • Consumers should have access to low-cost bank accounts with robust transaction capability, including: – No possibility of overdraft (e.g. checkless checking). – Robust debit card and online bill pay functionality (e.g. avoid need for money orders). Financial Institutions and Policy Makers Should Minimize Barriers to Banking Access • Consumers should not be excluded from opening a bank account because of unfair account screening (e.g. ChexSystems), or unrecognized (appropriate) ID. • Consumers should be able to open accounts online, at a location outside of a bank branch, while still meeting Know Your Customer (KYC) requirements. Bank On Coalitions are an Effective Mechanism for Connecting Consumers with Bank Accounts • Bank On coalitions are a primary tool for implementing the National Account Standards. • Coalitions serve as an effective way of identifying and implementing government integrations. • Bank On coalitions bring together municipalities, nonprofit organizations, and financial institutions. • Bank On coalitions illustrate the importance of municipalities providing leadership, sustainability and scale to financial empowerment initiatives. Government and Employer Integrations are the Best Approach to Achieving Scale • Bank On coalitions can work to identify and integrate bank account opening into government disbursement programs. • Bank On coalitions encourage governments and employers to make payments with direct deposit. A Learning Community of Bank On Coalitions Drive Thought Leadership and Share Best Practices • Local coalitions have the most knowledge about banking access. • The CFE Fund documents and articulates the sharing of best practices. • The CFE Fund synthesizes the experience of local Bank On coalitions to articulate a national perspective to inform policy. • The CFE Fund builds on insights from the field to sponsor original research and produce materials that spotlight issues, promote discussion and facilitate problem solving.
Bank On National Account Standards (2017-2018) TERMS
Core Features Transaction Account at Banking Institution
Checking account (including checkless checking); bank- or credit union-offered prepaid
Point of Sale (POS) Capability
Debit card/prepaid card
Minimum Opening Deposit
$25 or less If not waivable: $5 or less
Monthly Maintenance Fee
If waivable: $10 or less; offer at least two options to waive fee with a single transaction (e.g. direct deposit with no minimum deposit, online bill pay or debit card purchase)
Overdraft or Non-Sufficient Funds (NSF) Fees
None, structurally not possible (e.g. via checkless checking)
Dormancy or Inactivity Fees
Customer Service Branch Access
Free and unrestricted
Free and unrestricted (including live customer support)
Use of In-Network ATM
Free and unrestricted
Use of Out-of-Network ATM
$2.50 or less (not including local ATM fee)
Functionality Deposit Capability
Free in branch, at ATM, and direct deposit
Bill Pay by Customer
Bill Pay by Financial Institution
Free if available, otherwise at least four free money orders and/or cashier checks per month
Check Cashing for Checks Issued by that Bank
Online and Mobile Banking
Free paper (or electronic with consumer consent)
Insured by FDIC or NCUSIF
Strongly Recommended Features New Account Screening (e.g. ChexSystems, Early Warning Services)
Only deny new customers for past incidences of actual fraud
Alternative IDs (Municipal, Consular, etc.)
Accept alternative IDs
Remote Account Opening
Accounts can be opened remotely
Linked Savings Accounts
Free savings accounts and account transfers
Recommended Features Mobile Deposits
Immediate availability for known customers cashing government, payroll, or same-bank checks
$1.60 or less (based on U.S. Postal Service rate)
Remittances (International Wire)
Competitively priced ($5.00 â€“ $20.00, depending on country)
Credit-Building Product Offerings
Secured credit card or secured personal loan, e.g.
Bank On Coalition Financial Institution Partnerships: Statement of Principles
This Statement of Principles is a template for semi-formally articulating partnership expectations between local Bank On Coalitions and financial institutions. The document is meant to be edited for local purposes; it outlines shared goals as well as guidelines for product offerings and visibility, metrics and data reporting, and Coalition support. Click here to download a customizable Word version.
Shared Goals • (Bank On Coalition Name) is dedicated to helping improve the financial stability of the unbanked and underbanked residents of our community by connecting them to safe and affordable mainstream accounts in banks and credit unions, raising public awareness of these efforts and opportunities, and otherwise expanding access to financial education and other financial empowerment opportunities. • Partnerships are key to Bank On success, and we welcome financial institutions serving the consumer marketplace in our community who share these goals, support our Coalition efforts, and adhere to this Statement of Principles. Product Offering and Availability • Either currently or in the near future, partnering financial institutions should offer the public, in all of its community branch locations and online, access to a transactional account that meets Bank On National Bank Standards. These Standards, produced and disseminated by the Cities for Financial Empowerment Fund, highlight core and recommended features, functionalities, and protections. • Accounts meeting Bank On Standards should be able to be opened and accessed by consumers in the same manner as other product offerings of the financial institution, both in branch locations and online. • Sales incentives shall not discourage or otherwise prejudice the opening of accounts that meet Bank On Standards, nor should they specifically target customers opening accounts meeting Bank On Standards for other product upselling. Account Awareness and Visibility • Accounts meeting Bank On Standards should be positioned and available side by side with other product offerings of the financial institution, both in branch locations and online, so as not to discourage their visibility and to allow for product comparison. • Financial institutions, on their own and/or with the assistance of Coalition support, will make reasonable affirmative efforts to train branch and other customer support staff regarding the existence and features of accounts that meet Bank On Standards. Metrics and Data Reporting • Financial institution partners should make reasonable efforts to track and report their Coalition support, including reporting aggregate data on accounts meeting Bank On Standards through national portals established by the Cities for Financial Empowerment Fund. Coalition Support • Financial institution partners should support Coalition efforts, ideally designating an empowered individual as a primary point of contact. • As reasonably feasible, this support includes facilitating branch connections, supporting marketing and communications efforts, and underwriting Coalition efforts and convenings.
Bank On National Account Standards Validation and Certification: Frequently Asked Questions Accounts meeting the National Account Standards are now available at
49 states + Washington, DC
1. FAQs: National Account Standard Certification What are the Bank On National Account Standards? The Cities for Financial Empowerment Fund (CFE Fund) first issued Bank On National Account Standards in October 2015, and released an updated version of the Standards in 2017. Compiled with input from local coalitions, financial institutions, regulators, advocates, and researchers across the country, they offer specific guidance on consumer transaction accounts appropriate for financial institution partnerships with local Bank On coalitions. The Standards include core, strongly recommended, and recommended features that address cost, functionality, and consumer safety. They establish an ambitious, but achievable, baseline for safe, affordable, and appropriate accounts that meet the needs of consumers with low incomes, particularly those outside of the financial mainstream. How do I know if a bank or credit union account meets the Standards? In 2017, the CFE Fund announced a national account certification process. Available free online, financial institutions can submit for validation accounts that they believe meet the Standards. Once validated by the CFE Fund’s third party evaluator, the National Consumer Law Center, as meeting Bank On Standards, financial institutions will receive a Bank On seal of approval for marketing and outreach purposes; national recognition highlighting the account’s safety, affordability, and functionality; and opportunities to partner with local Bank On coalitions and other national stakeholders. How can stakeholders use the Bank On National Account Standards certification? • Financial institutions can use the Standards and certification to highlight their commitment to safe and affordable accounts across all branches and local partnerships, as well as in product development planning. National certification also relieves financial institutions from pressure to modify products locally. • Local coalitions can use national certification to identify appropriate products to which to connect their residents struggling outside of the mainstream banking system. Certification of nationally recognized standards also offers a clear basis for conversations with financial institutions that do not yet offer a certified product. What are reporting requirements for Bank On certified accounts? There are no national reporting requirements for Bank On certified accounts. However, the CFE Fund is currently partnering with the Federal Reserve Bank of St. Louis and a few banking institutions to pilot a centralized national reporting portal that could allow for voluntary reporting in the near future. Such basic data, such as number of certified accounts opened in a given reporting period, will also be relevant to Community Reinvestment Act regulatory examinations. Of course, local Coalitions and financial institutions are free to partner on data as they please, but once the pilot phase is complete, financial institutions will be able to submit to one central national portal basic data from their Bank On certified accounts.
(FAQs continued on page 6)
Chapter 4: Bank On National Account Standards Validation and Certification: Frequently Asked Questions (Continued from page 5)
2. FAQs: The Validation Process How does the account validation process work? Using the free CFE Fund web portal, financial institutions submit their account terms and contact information, as well as any additional information that demonstrates that the account meets Bank On National Account Standards core features. The CFE Fund’s independent evaluator, the National Consumer Law Center (NCLC), compares account features to the “core features” outlined in the Standards. Both the “strongly recommended” and “recommended” features are intended to provide additional guidance for Bank On programs when partnering with financial institutions, but are not required for certification. The validation process is “up or down”– accounts either meet all core Standards features or they do not. Who can submit a financial product for certification review? Banks and credit unions are eligible to submit one or more of their products for validation as meeting Bank On National Account Standards. Local Bank On programs and partners can work with and encourage financial institutions to apply for validation, but the application itself may only be submitted by the financial institution. The CFE Fund welcomes the opportunity to meet with financial institutions to discuss their product and the Standards and answer any questions. Please contact David Rothstein, Principal, for more information. Who conducts the validation? The CFE Fund has partnered with a third-party nonprofit evaluator, the National Consumer Law Center, to evaluate Bank On accounts. Upon application, financial institutions may receive questions from NCLC and/or the CFE Fund to clarify product details. How will I learn the result of the validation process? Are results made public? The CFE Fund will contact applicant financial institutions promptly with the results of the validation process. Accounts that are not certified are not announced publicly – the CFE Fund will only notify the financial institution applicant. The CFE Fund’s goal is to certify as many products as possible, and will work with financial institutions to provide guidance for meeting the core features of the Standards. What are the benefits of getting a product validated and certified? In addition to providing appropriate and safe accounts to millions of customers in need, financial institutions whose accounts are validated as meeting Bank On National Account Standards are officially and publicly certified as a Bank On Approved Account. Such certification will provide a basis for robust local coalition affiliations and programming opportunities. Additionally, financial institutions can use their product-specific national certification seal provided by the CFE Fund in online marketing, branch signage, and other collateral materials to communicate and highlight that their account meets these widely-accepted Standards. The CFE Fund will promote Bank On certified accounts through inclusion in Bank On materials and in communications with local Bank On coalitions, as well as through assets like CFE Fund websites and social media outlets. The CFE Fund will also connect financial institutions to opportunities to partner with local Bank On coalitions and national Bank On stakeholders, where appropriate. Additionally, financial institutions with certified Bank On accounts will be eligible to participate voluntarily in a streamlined, national data collection effort to be launched in 2017, described above. My financial institution is located in multiple cities or states. Does the product need to be validated for each market? No, this is a national certification, applying to products available across a financial institution’s entire branch network. Note that the certification applies only to the product submitted and not to the entire suite of a financial institution’s offerings or to the financial institution as a whole.
(FAQs continued on page 7)
Chapter 4: Bank On National Account Standards Validation and Certification: Frequently Asked Questions (Continued from page 6)
3. FAQs: The Standards Themselves Does an account need to be free? No. The Standards’ core requirements ask only that monthly maintenance fees not exceed $5 if there is no waivable fee option. If there is a waivable fee option through direct deposit, online bill pay or debit card purchase, the Standards accept monthly maintenance fees as high as $10. Are prepaid debit cards eligible for Bank On National Account Standards validation? Yes. The Standards do not distinguish products based upon whether they are structured as a prepaid card or other type of account. Instead, financial products are evaluated against the articulated standards. Note that the standards do require that the product be offered by a banking institution with branches. Do financial institutions need to offer both free paper and electronic statements? No. The Standards require only that consumers be offered free paper statements. However, if a financial institution also offers electronic statements, the Standards require both that they also be free and they be offered as a substitute for paper statements on a voluntary basis by a customer. While the Standards do not allow for any statement charges, note that a financial institution of course can include such costs within allowable monthly fee limits. How can financial institutions address dormant accounts while remaining compliant with the Standards? The Standards require that there are no charges for dormancy or non-usage. However, a financial institution can establish a time period after which it may refund dormant account funds, for free, to the consumer. What are the bill pay options under the Bank On National Account Standards? Transactional accounts must meet consumers’ needs, which include paying bills and vendors of different types. The Standards require two free bill pay features. First, the product must allow bill pay by the customer, to a vendor, using their 16-digit debit card account number. Second, the financial institution must have a free institutional or subcontracted bill pay system that allows customers to send payments to any person or business (e.g. by electronically generating a paper check) OR, at minimum, allow customers four free money orders or cashier’s checks per month. Can the account have overdraft or nonsufficient funds fees? No, the Standards do not allow for overdraft or nonsufficient funds fees, period. The Standards do not allow for grace period, warning, or fee reversal exceptions to this requirement. Of course, transactions may be denied when an account balance is insufficient, and a financial institution retains the right to cancel a customer’s account after repeated, purposeful overdraw attempts. What does “free and unrestricted” mean when it comes to the Telephone Banking core feature? This standard is designed to ensure that these account holders are not penalized with additional fees or more limited access for existing telephone banking services, or that they are not charged a fee to do something on the phone that is free at a branch. Thus, if the bank provides free balance inquiries or other customer service representative services to holders of other institutional accounts, as almost all do, they cannot add a charge or restrict such calls for these account holders.
Please contact us … we’ll be happy to answer your questions quickly, and will also continue to update these FAQ’s to help your colleagues! 7
Talking Among Ourselves: The Bank On Listserv
One of our greatest resources in the Bank On community is each other. By sharing our experiences, questions, frustrations, and best practices, we each advance our own coalition efforts, as well as our larger community. The CFE Fund’s Bank On Listserv is designed to do just that. Join now to continue the conversation!
Who can join? Bank On coalition members, including government, nonprofit, and financial institution partners, can all participate in the Listserv, which will be moderated by the CFE Fund. Financial institutions, academics, and other stakeholders interested in banking access efforts who are not currently part of Bank On coalitions are also welcome to join the community.
How do I sign up? The CFE Fund’s Bank On Listserv is managed through Google Groups. Just use this link to join: https://groups.google.com/d/forum/bankon. Note: Google Groups requires users to have Google accounts. If you do not have a Google account, you can create one with your non-Gmail address. This will allow you to receive listserv emails at your primary work email address, even if it is not Gmail. 1. Once you are logged in with a Google account, you will be prompted to “apply for membership.” You will be asked to share your local Bank On coalition affiliation(s) and role, and select how often you want to receive listserv emails (i.e. abridged, digest, individual emails). 2. Upon signing up for the listserv, you should be approved within a few days and will be able to send and receive listserv emails from email@example.com. 3. Note: For government email addresses, some content may be delayed and/or attachments may not come through. These are settings that are not in our control and you may want to use a Google account address if this is an issue.
How should I use the Listserv? The Listserv is dedicated to technical assistance. It’s a place to ask questions and share resources with the community. For example, conversation topics might include: • Does anyone have a flier for a Bank On event that they felt was particularly effective? • Has anyone held a press event for a Bank On launch? • Who serves on your advisory committee and how often do you meet? The CFE Fund will also initiate conversations on a range of topics to solicit and share best practices from the field, which will inform the content for future Bank On Playbook resources. This Listserv is a technical assistance resource, not a forum for direct fundraising appeals, news stories, or advocacy. To view and search for archived email threads, including attached files, you can visit the group webpage: https://groups.google.com/d/forum/bankon.
Stay tuned for the next Chapter!