356 - Federal Deposit Insurance Corporation
356MinutesofThe Meetingof the FDIC AdvisoryCommitteeon EconomicInclusionof theFederalDepositInsuranceCorporationHeld in the Board uildingD.C.Open to Public ObservationApril24, 2014 - 9:04 A.M.The meeting of the FDIC Advisory Committee on EconomicInclusion ("ComE-IN" or "Committee") was ca"lled to order byMartin J. Gruenberg, Chairman of the Board of Directors of theFederal Deposit Insurance Corporation("Corporation" or "FDIC").The members of ComE-IN present at the meeting were Robert A.Annibale, Global Director, Citi Microfinance and CommunityDevelopment; Michael S. Barr, Professor of Law, University ofMichigan Law School; Ted Beck, President and Chief ExecutiveOfficer ("CEO"), National Endowment for Financial Education;Kelvin Boston, Executive Producer and Host of PBS' Moneywise withKelvin Boston; Jose Cisneros, Treasurer, City and County of SanFrancisco, California; Martin Eakes, CEO, Self-Help/CenterforResponsible Lending, Durham, North Carolina; Rev. Dr. Floyd H.Flake, Senior Pastor, Greater Allen AME Cathedral of New York;Andrea Levere, President, Corporation for Enterprise Development,Washington, D.C.; Patricia A. McCoy, Director of the InsuranceLaw Center and the Connecticut Mutual Professor of Law,University of Connecticut Law; Alden J.McDonald,Jr., Presidentand CEO, Liberty Bank and Trust, New Orleans, Louisiana; Bruce D.Murphy, Executive Vice President and President, CommunityDevelopment Banking, KeyBank National Association; John W. Ryan,Executive Vice President, Conference of State Bank Supervisors;Phillip L. Swagel, Professor in International Economic Policy,University of Maryland, Senior Fellow at the Milken Institute anda visiting scholar at the American Enterprise Institute; and John
357C. Weicher, Director,Financial Markets.HudsonInstitute'sCenterfor HousingandEster R. Fuchs, Professor, School of International andPublic Affairs, Columbia University; Wade Henderson, Presidentand CEO, Leadership Conference on Civil Rights, and Counselor tothe Leadership Conference on Civil Rights Education Fund; WadeHenderson, President and CEO, Leadership Conference on CivilRights, and Counselor to the Leadership Conference on CivilRights Education Fund; Manuel Orozco, Senior Associate at theInter-American Dialogue, and Senior Researcher, Institute for theStudy of International Migration, Georgetown University;J. Michael Shepherd, Chairman and CEO, Bank of the West andBancWest Corporation; Robert K. Steel, Deputy Mayor for EconomicDevelopment, The City of New York; and Peter Tufano, Peter MooresDean and Professor of Finance, Said Business School, OxfordUniversity andFounder and CEO of 020 Fund, were absent from themeeting.Members of the Corporation's Board of Directors present atthe meeting were Martin J. Gruenberg, Chairman, and Jeremiah o.Norton, Director (Appointive).Roberta K. McInerney, DesignatedFederal Officer for the Committee and Deputy General Counsel,Corporate, Consumer, Insurance, and Legislation Branch, FDICLegal Division, also was present at the meeting.Corporation staff who attended the meeting included Willa M.Allen, James L. Anderson, Michael L. Bachman, Michael W. Briggs,Lariece M. Brown, Susan Burhousel Alexander S. Cheng, Karyen Chu,Patricia A. Colohan, Kymberly K. Copa, Carolyn D. Curran, DebraA. Decker, Willie B. Donaldson, Doreen R. Eberley, Keith S.Ernst, Robert E. Feldman, Lekeshia Frasure, Janet R. Gordon,Bobbie Gray, Shannon N. Greco, Matthew Homer, Shamara L. Humbles,Craig R. Jarvill, Ron Jauregui, Kathy Kalser, Arleas Upton Kea,Sally J. Kearney, Cheh Kim, Alan W. Levy, Alicia Lloro,Christopher Lucas, Jonathan N. Miller, Robert W. Mooney, PhoebeD. Morse, Thomas E. Nixon, Janet V. Norcom, Elizabeth Ortiz,Yazmin E. Osaki, Mark E. Pearce, Sylvia H. Plunkett, Luke W.Reynolds, Sherrie Rhine, Jay Rosenstein, Barbara A. Ryan, RichardM. Schwartz, Kenneth Shaw, Patience R. Singleton, Lori Thompson,Lauren A. Whitaker, and James Yagley.William A. Rowe, III, Deputy to the Chief of Staff andLiaison to the FDIC, Grovetta N. Gardineer, and Barry Wides,Office of the Comptroller of the Currency, were also presentthe meeting.Aprilat24, 2014
358ChairmanGruenbergopenedand presidedat the meeting.Chairman Gruenberg began by introducing two new members tothe Committee.First, he welcomed Patricia A. McCoy to theCommittee.He noted that she is a Professor of Law at theUniversity of Connecticut School of Law, serves as Director ofthe Insurance Law Center at the School, has had a distinguishedacademic career with a particular focus on consumer protection inthe financial services area, and, from 2010 to 2011, served atthe United States Department of the Treasury where she helpedcreate the Consumer Financial Protection Bureau ("CFPB").Shelater served as the CFPB's first Assistant Director for MortgageMarkets.He then welcomed Phillip L. Swagel to the Committee.Professor Swagel is a Professor of International Economic Policyat the University of Maryland's School of Public Policy, directsthe University's Thomas Schelling Distinguished Visitor Series,is a non-resident scholar at the American Enterprise Institute,served as Assistant Secretary for Economic Policy at theDepartment of Treasury from 2006 to 2009, and previously servedas Chief of Staff and senior economist at the White House Councilof Economic Advisers.Next, Chairman Gruenberg provided an overview of the agenda,advising that the meeting would focus on new efforts to expandbanking services to consumers.With respect to the first panel,he recalled that the Committee previously discussed safeaccounts; that two institutions - Bank of America, NationalAssociation("BAC"), Charlotte, North Carolina, and Union Bank,National Association, San Francisco, California - wereintroducing account-based debit card products consistent with theFDIC's model transaction accounts; and that BAC and Union Bankrepresentatives on the first panel would describe the structureof these accounts, outline the research and strategy that shapedtheir creation, and summarize consumer reaction.The secondpanel would present a paper describing the potential of mobilebanking to expand access to the banking system, he advised.Thepaper was the first of its kind, he reported, and would provide asolid starting point for future initiatives.With respect to thethird panel, he announced that the CFPB and FDIC were introducinga new financial education program designed for primary andsecondary level students.The new program was built upon theFDIC's existing Money Smart Program but was designed to draw inteachers and parents as well as students.He advised that thefourth panel would deal with consumer demand for small-dollarcredit.Chairman Gruenberg then introduced Jonathan Miller,Deputy Director, Policy and Research, Division of Depositor andApril24, 2014
359Consumer Protectionon "Safe Accounts."("DCP"), moderatorfor the panel discussionMr. Miller noted that the FDIC and the Committee previouslydiscussed efforts to bring unbanked and underbanked householdsinto mainstream banking systems; that, with the Committee's help,the FDIC designed a safe transaction account template andsubsequently launched the Model Safe Accounts Pilot Program totest and refine the template; the Pilot Program confirmed thatsafe accounts performed on par with or better than othertransaction accounts while bringing unbanked and underbankedconsumers into the banking system; that, armed with its findings,FDIC staff met with financial institutions to explain the resultsof the Pilot Program; that various institutions agreed to designand market safe accounts; and that today's panelists, as earlyadopters, would describe initial consumer reaction to safeaccounts.Mr. Miller then introduced the panel members:ThongNguyen, Retail Banking Executive, BAC; and Rogger LaCruz, VicePresident, Senior Product Manager for Retail Deposits, UnionBank.Mr. Nguyen noted that BAC has approximately 70 millioncustomers in 50 million households in the United States; that asmall percentage(approximately three to four million customers)consistently overdraft their accounts; that customers incurringoverdraft fees often contact customer service centers atsignificant cost to BAC; and, even when BAC reimburses overdraftfees, customer satisfaction suffers.BAC therefore decided tocreate a product to resolve these issues with the primary goalbeing to "do the right thing."Their efforts extended over athree-year period and included meetings with advocacy groups aswell as in-depth customer studies.Based upon their findings,BAC rolled-out "SafeBalance Banking," a robust mobile platformthat has many of the same features and benefits of BAC'straditional checking accounts but is designed to help customersavoid overdraft fees.The product has a fixed monthly fee of 4.95, provides full access to tellers and ATMs, provides debitcards with a zero liability guarantee and optional photosecurity, and has full online and mobile banking access.Heemphasized that timing issues can catch customers by surprise andso BAC worked to eliminate timing issues related to this product.Customers can pay individuals or businesses using their debitcard in person, online and by mobile transfers, or through onlinebill pay but, by allowing transactions to be approved only whenthe customer has sufficient funds in the account, customers areprevented from falling into overdraft or insufficient-fundsstatus.Checks are issued to recipients only after the fundsApril24, 2014
360have been withdrawn by the customer and, with respect to ATMs,consumers cannot withdraw funds they do not have in theiraccount.BAC also provides online and mobile alerts so customerscan avoid timing issues altogether.In short, Mr. Nguyen saidBAC created a full-feature, online, mobile product with fullaccess to the banking system, banking centers, and ATMs, butwithout the threat of destroying the customer's liquidity.Moreover, BAC partnered with the Khan Academy to deliver moneymanagement training to their customers.Customers who encountermoney-managementproblems are encouraged to join the program and,even though the program is just starting, several thousandaccounts have joined the program already.Mr. LaCruz then outlined Union Bank's efforts to create the"Union Bank Access Account" ("Access Account").Driven by itscore belief to "Do the right thing for its customers" and basedupon its review of the 2009 and 2011 FDIC Unbanked andUnderbanked Households Surveys, Union Bank designed the AccessAccount to demonstrate its commitment to providing products thatserve the needs of the low-to-moderate income ("LMI") segment andother customers who may not qualify for a traditional account.He described the key features of the Access Account as follows:no direct deposit requirements, no service fees with directdeposits, no minimum balance requirements, unlimited discountedmoney orders in lieu of paper checks, no overdraft orinsufficient-fundfees, and no hidden fees.He emphasized thatAccess Accounts are checkless which means customers will not becaught in the position of bouncing checks.Mr. LaCruz then directed the Committee's attention to thechallenges consumers face when they are reported to ChexSystemsa network of financial institutions that regularly share andconsolidate information regarding closed checking and savingsaccounts for the stated purpose of enabling them to assess therisk of opening new accounts.Prior to opening an account for aconsumer, financial institutions access ChexSystems and, if theconsumer has been reported, typically decline the account withappropriate disclosures.Thus, this segment of the populationhas difficulty accessing mainstream banking.Mr. LaCruz reportedthat consumers who are in ChexSystems may nonetheless qualify forthe Account Access product as long as they are not in ChexSystemsdue to fraudulent activity . He next discussed Union Bank'sanalysis when setting minimum deposit requirements.He explainedthat monthly service fees are 5.00 (with online statements) or 6.00 (with paper statements) though the account is free if thecustomer has a direct deposit minimum of 25.00 per month;approximately fifty percent of its customers have direct depositApril24, 2014
361and thus the accounts are free to most customers.The Bank hasobserved that consumers who open accounts with lesser minimumrequirements typically receive a first statement from their bankshowing a negative balance and so walk-away from the account orfall into overdraft status; the account is closed; the consumeris reported to ChexSystems, making it difficult to open futureaccounts and pushing the consumers out of the banking system andinto check-cashing storefronts or alternative financial products.Thus, Account Access was designed with "guardrails" to helpcustomers manage their accounts yet customers have full access totellers, ATMs, online banking, and mobile banking.He closed hispresentation by describing Union Bank's efforts to reach unbankedand underbanked consumers.These efforts included the use ofeasy-to-understanddisclosure formats recommended by The PewCharitable Trusts ("Pew"), targeted marketing to reach at-riskconsumers, outreach to local community groups, and specializedin-house training.The Committee applauded Mr. Nguyen's and Mr. LaCruz'sefforts to provide affordable banking services to LMI consumersand agreed that the accounts serve as useful entry points forthese consumers.The Committee then discussed at length theeconomics underlying safe accounts, particularly focusing on thesustainability and "marginal costs" of safe accounts.As towhether the accounts were sustainable over the long term, Mr.Nguyen advised that BAC's approach was to "break-even."Heexplained that, due to demographics, the product is targeted toBAC's existing customers but, given that BAC serves approximately50 million households, that is a significant segment.Theirprimary objective, then, is to focus on serving current customerswho are encountering money management issues.He explained thatthe alternatives - standing aside while customers pile-upoverdraft charges or turning consumers away - were unpalatable.He also saidit would be helpful to remember that many consumercomplaints concern fees, most of the fees are incurred by thevery population safe accounts are designed to help, and safeaccounts can help avoid complaints and permit the bank to focuson other matters.Mr. LaCruz agreed, noting that Account Access is designed toserve and retain current customers but that, over time, UnionBank believes the product will attract new customers to the bank.He noted that the program has been in place for just 11 monthsand they opened over 6,000 accounts.He emphasized that it isimportant to get the word out to customers because the goal is toreach customers before they have problems with ChexSystems or areafraid to open a checking account.Customers were excited toApril24, 2014
362hear of the program, he reported, and some customers establishedaccounts with high-dollar deposits, suggesting that they hadstashed funds in their homes because they did not have a bankaccount.The typical user of these accounts has a smaller amountof savings compared to their general customer base, he noted.Consequently, Union Bank hopes to design a savings product thatcan go hand-in-hand with Access Account.As the bank learnsabout these customers' needs, the bank will be better situated toaddress their savings concerns.Continuing on the theme of sustainability, the Committeediscussed the challenges faced by banks having a differentmarginal cost of funds than the panelists, which might result inmonthly fees higher than the 4.95 or 5.00 mentioned by thepanelists; considered whether reliance on third-party vendors forcomponents of a program would increase the costs; and urged thepanelists to share substantive cost analyses of the safe accouniwith the FDIC's research staff.The Committee members then asked Mr. Nguyen to expand uponthe challenges BAC encountered with its "no overdraft" approachin the context of point-of-sale arrangements.Mr. Nguyen advisedthat, with respect to operational implementation of the "nooverdraft" approach, BAC had not encountered problems.Althoughsome customers were chagrined when an attempted point-of-saletransaction was denied (even though the denial meant the customeravoided overdraft fees), most customers found it preferable toavoid going into overdraft status even if the attempted point-ofsale acquisition failed.The Committee also discussed, in turn, the success of the"BankOn" program - a program offering services to unbanked andunderbanked households; the large percentage of consumers who areunbanked because they are in ChexSystems; and consumer education.With respect to education, the Committee members expressedconcern that consumers are unfamiliar with safe accounts.Mr.Nguyen agreed that outreach and engagement are essential, advisedthat the educational program developed with the Kahn Academy iscalled "Better Money Habits" at bettermoneyhabits.com,and thatBAC strives to help customers find the product that is bestsuited to their needs.Mr. LaCruz concurred, noting that UnionBank spent significant time with consumers in their homes in aneffort to learn what would be most helpful and found thateducation is essential.April24, 2014
363Chairman Gruenberg advised that the meeting would continuewith Keith Ernst, Associate Director for Consumer Research, DCP,moderating the second panel.Mr. Ernst first described the context of the white paper onMobile Financial Services ("MFS") and the progress made on thepaper since the last Committee meeting.He then explained thatthe paper applies a three-part analytical framework forevaluating MFS' impact on economic inclusion and also identifiesseven broad takeaways that will increase the economic inclusionpotential of MFS.Mr. Ernst explained that the paper examineshow technology may increase access for the underbanked as well aspresent opportunities for growth.He stated that the paper alsoexplores the opportunities and challenges presented by thecurrent technologies, regulatory requirements, and businessenvironment.Mr. Ernst then advised that Susan Burhouse, Senior ConsumerResearcher, DCP, would discuss some of the challenges to economicinclusion, define the technology, and share data on the public'suse of MFS, after which Yazmin Osaki, Senior Consumer ResearchAssociate, DCP, would provide additional details about thespecific analytical framework described in the paper.He statedthat Matt Homer, Policy Analyst, DCP, would conclude thepresentation with a discussion of the takeaways from the whitepaper.Ms. Burhouse stated that, although the use of MFS has becomemore widespread, it is not always designed for use in ways thatincrease economic inclusion.Ms. Burhouse emphasized that theFDIC's research suggests that opportunities exist to fine-tuneMFS offerings to better assist the underserved.Next, Ms.Burhouse explained that profitability and fraud issues presentbroader challenges to economic inclusion efforts.Ms. Burhousealso noted that some bankers perceive the regulatory environmentand customer identification requirements as additionalchallenges.She stated that customer awareness regarding productavailability is another concern for institutions.Recalling thatmany of the small dollar loan and safe account pilot banks havestruggled with targeting products and disseminating informationto the unbanked and underbanked consumers, Ms. Burhouse suggestedthat improvements in marketing methods might resolve some of theissues related to customer awareness.Ms. Burhouse then reiterated that challenges with mainstreambanking cause some consumers to resort to alternative financialservices ("AFS") instead of banks.Citing a 2011 study by PewApril24, 2014
364that surveyed workers who are paid in cash only, Ms. Burhousepointed out that even the method through which consumers receivetheir income
Minutes of The Meeting of the FDIC Advisory Committee on Economic Inclusion of the Federal Deposit Insurance Corporation Held in the Board Room Federal Deposit Insurance Corporation Building Washington, D.C. Open to Public Observation April 24, 2014 9:04 A.M. The meeting of the FDIC Advisory Committee on Economic
1.2 European history of deposit insurance 11 1.3 Deposit insurance as an element in the financial safety net 12 2 Deposit insurance fundamentals 15 2.1 Aims and requirements of a modern deposit insurance scheme 15 2.1.1 Aims of deposit insurance 15 2.1.2 Requirements of a deposit insurance scheme 17 2.2 Guarantee promises 19
NEW HAMPSHIRE CHAPTER 356-B CONDOMINIUM ACT I. General Principles Section 356-B:1 356-B:1 Short Title. – This chapter shall be known and may be cited as the ""Condominium Act''. Source. 1977, 468:1, eff. Sept. 10, 1977. Section 356-B:2 356-B:2 Application.
Deposit Insurance Corporation, to chair a working group that would carry out the task of setting out guidance for effective deposit insurance systems. The final report of the Working Group on Deposit Insurance was discussed and endorsed by the Forum in London, on September 7, 2001. The FSF report on deposit insurance is built on three general .
The Cashier Office will provide pre‐numbered 3‐part deposit slips and plastic tamper resistant deposit bags for the bank deposit. The first 3 digits of the deposit slip is a location number and will identify your department to the Cashiers and the bank. The last 4 digits is a sequential deposit number. All bank deposit slips and bags must .
01/13 consol elec deposit 1 30.00 01/13 deposit intuit pymt soln boyette springs homeow 60.00 01/13 consol elec bill pay deposit 3 90.00 01/17 deposit intuit pymt soln boyette springs homeow 30.00 01/17 consol elec bill pay deposit 7 210.00 01/18 deposit intuit pymt soln boyette springs homeow 60.00 01/18 consol elec bill pay deposit 8 240.00
Financial inclusion and deposit insurance: It stands to reason that deposit insurance should promote financial inclusion by bolstering confidence in financial institutions and potentially leading to greater savings among the poor. Access to deposit insurance should provide a measure of protection to small savers, provided they are informed
discusses main features of the deposit insurance schemes and section 5 concludes. The database, country details and sources are presented in the appendix. 2. Deposit insurance adoption As Demirgüç-Kunt, Kane and Laeven (2005) point out, every country has a de facto implicit deposit insurance scheme (IDIS) in place since governments get .
Nutrition of ruminants Developing production systems for ruminants using tropical feed resources requires an understanding of the relative roles and nutrient needs of the two-compartment system represented by the symbiotic relationship between rumen micro-organisms and the host animal. Fibre-rich, low-protein forages and crop residues are the most abundant and appropriate feeds for ruminants .
