The Board of Governors of the
Federal Reserve System, Federal Deposit Insurance Corporation, Federal
Home Loan Bank Board, National Credit Union Administration, Office
of the Comptroller of the Currency, Conference of State Bank Supervisors,
National Association of State Credit Union Supervisors, and National
Association of State Savings and Loan Supervisors are issuing this
joint policy statement to encourage the efforts of trade associations
and individual depository institutions regarding the offering of “basic
financial services.”
1
The economic environment in which financial institutions
operate has changed over the past few years, due in part to increased
competition from outside the traditional depository institution structure,
increased cost of funds following deregulation of interest rates,
and interest rate volatility. As a consequence, many institutions
have had to adopt new strategies to market their services, generate
income, manage risk, and reduce costs. Some institutions have begun
to explicitly price their products, consolidate or eliminate services
they believe to be unprofitable, and close branch offices. In many
instances, institutions have increased service charges, imposed new
fees, and raised minimum-balance requirements.
While such adaptation may be a necessary response
to competitive markets, considerable concern has developed about the
potential impact of these changes in effectively denying or reducing
convenient access of many individuals to the payments system and to
safe depositories for small savings. Because credit availability is
often dependent on an account relationship with a financial institution,
access to credit for low-income or young consumers may also be adversely
affected.
While a significant number of consumers have never had
a deposit account, some research studies reflect declines in account
ownership that may be cause for concern. For example, between 1977
and 1983 the proportion of families headed by a younger person having
checking accounts decreased, as did the number of families from the
lowest income group, regardless of age. The proportion of young families
having either a savings or a checking account also declined. While
the cause of these declines is not always clear, the surveys do suggest
that a significant number of individuals or families do not have a
deposit relationship of any kind.
Legislation dealing with basic financial services has
been introduced at both the federal and state level as a result of
these concerns. The industry has also responded. Many financial institutions
have independently undertaken to develop and implement new measures
to meet minimum consumer needs. They are offering basic services,
such as low-cost transaction and savings accounts with low or no minimum
balances, accounts for consumers who use a limited number of checks
or drafts, and other accounts on which minimal charges are made for
account maintenance. Institutions that have for years offered such
services to particular groups of customers are now advertising their
availability more widely. Other institutions are exploring and finding
ways to maintain a physical presence in low- and moderate-income neighborhoods
even while reducing the expense normally associated with full branch
facilities. Trade groups too have joined in these efforts to encourage
the offering of such services at affordable prices. The American Bankers
Association and Consumer Bankers Association, for example, have called
upon their members to address the continuing interest in basic banking
services.
The member agencies of the Federal Financial Institutions
Examination Council and the associations of state supervisors wish
to encourage such efforts by trade associations and individual depository
institutions that promote the offering of basic financial services,
consistent with safe and sound business practices. While the specific
type of services will, of course, vary because of differences in local
needs and in the characteristics of individual institutions, we encourage
efforts to meet certain minimum needs of all consumers, in particular—
- the need for a safe and accessible place to keep
money,
- the need for a way to obtain cash (including, for
example, the cashing of government checks), and
- the need for a way to make third-party payments.
We believe that industry trade associations
have a key role to play in this effort, and are in a position to encourage
a constructive response without the rigidities of legislation or regulation.
We realize that some associations have such programs already underway.
These programs could usefully—
- encourage members to offer and appropriately publicize
low-cost basic financial services such as those listed above,
- survey the current availability of such services
among member institutions, and
- make available to members not providing such services
material reflecting the successful experiences of other organizations.
Joint policy statement of March 3, 1987.