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JUNE 2021BLACKLISTEDHow ChexSystems Contributes toSystemic Financial Exclusion

TABLE OFCONTENTSI. EXECUTIVE SUMMARY03II. INTRODUCTION04Ab out the San Francisco Office ofFinancial EmpowermentBackground on ChexSystemsIII. KEY ISSUES IDENTIFIED WITH CHEXSYSTEMSUnclear, Unfair and Unequal TreatmentAmbiguous Impact of InquiriesImpossible ResolutionIndividual Impacts, Systemic ExclusionIV. RECOMMENDATIONS FOR REFORM0405070711121416

03Blacklisted: How ChexSystems Contributes to Systemic Financial ExclusionI.II.III.IV.I. EXECUTIVESUMMARYUnder the leadership of Treasurer JoséCisneros, the San Francisco Office of FinancialEmpowerment (OFE) strives to ensure thatevery San Franciscan has access to a safe andaffordable bank account. Unbanked rates havefallen both locally and nationally, yet many of ourresidents continue to live outside of the financialmainstream, relying on expensive and oftenpredatory fringe financial services. Research fromthe Federal Deposit Insurance Corporation (FDIC)finding that nearly 50 percent of unbanked peoplewere previously banked led OFE to embark on aresearch initiative to better understand why someconsumers – especially those with a past bankinghistory – remain unbanked.This initiative revealed deep problems associatedwith bank account screening consumer reportingagencies, which provide financial institutionswith (mostly negative) information about people’sbanking histories and are used by banks and creditunions to decide whether to allow someone to openan account. OFE examined how account screeningpractices contribute to financial exclusion, focusingon the use of ChexSystems, one of the twoagencies that dominate this industry. Followingconsumer and stakeholder interviews and surveysand review of ChexSystems reports for financialcoaching clients, OFE found numerous flaws withthe system’s current design and implementation,including a lack of consumer awareness, unfairand unequal outcomes, and a dispute resolutionprocess that is nearly impossible to navigate.Involuntary account closures and ChexSystemsrecords can be devastating, and the use of thesesystems has resulted in a regime that systemicallyexcludes consumers, with a disproportionateimpact on Black consumers. To address the flawsin the system, OFE recommends urgent reforms toagencies like ChexSystems and the financialinstitutions that use them that will enhance thetransparency, accessibility, and fairness of thesystem. These reforms include creating clear anduniform definitions and policies related to bankinghistory data, reducing the impact of overdrafts onaccount closures and denials, eliminating the useof account screening consumer reporting agenciesfor customers opening Bank On certified accounts,and developing robust resolution processes thatcreate pathways to banking for consumers. OFE alsooutlines recommendations for financial coachesand others helping consumers navigate this opaqueaccount screening system, including making reviewof ChexSystems reports a standard practice andhelping clients overcome barriers related to thesereports and their use by banks and credit unions.

04Blacklisted: How ChexSystems Contributes to Systemic Financial ExclusionI.II.III.IV.II. INTRODUCTIONTreasurer José Cisneros and the Office of Financial Empowerment(OFE) launched the groundbreaking Bank On San Francisco programnearly 15 years ago after realizing that many residents of San Franciscohad no bank account (“unbanked”), and instead relied on costly fringefinancial products such as payday lenders and check cashers. Bank OnSan Francisco spurred a national movement and a national coalitionof cities working to improve access to safe and affordable bankaccounts for all who desire and need one. Bank On San Franciscoboasted strong initial success, with unbanked rates dropping from anestimated 15-20 percent in 2005i to 2.8 percent in 2019.iiHowever, unbanked rates remain persistently high for certainpopulations. For example, 42 percent of Black clients enter OFE’sfinancial coaching program unbanked, compared with 32 percentof clients overall. This local data reflects disparities in mainstreambanking access nationally, as 13.8 percent of Black householdsand 12.2 percent of Latinx households were unbanked as of 2019,compared to only 2.5 percent of white households.iiiAccording to the Federal Deposit Insurance Corporation (FDIC)’s mostrecent survey of household banking practices, slightly more than 50percent of people who are unbanked had a bank account at somepoint in the past.iv With so many previously banked people nowunbanked, it is clear that any effort to reduce unbanked rates mustrecognize this constituency and their concerns and needs.To understand why these individuals are currently unbanked, OFEembarked on a research initiative to study reasons why peopleremain unbanked, including debt collection and bank levies, fearsaround asset limits in public benefit programs, and distrust ofmainstream financial institutions. The focus of this follow-upreport is another systemic barrier to banking: the denial of customerapplications by banks based on negative consumer banking data –especially involuntary account closures – held in the records of bankaccount consumer account screening agencies like ChexSystems.ChexSystems, a subsidiary of Fidelity National Information ServicesABOUT THE SANFRANCISCO OFFICEOF FINANCIALEMPOWERMENTThe San Francisco Office ofFinancial Empowerment (OFE)is a unique private-publicpartnership housed withinthe Office of the Treasurer &Tax Collector that convenes,innovates and advocates tostrengthen the economicsecurity and mobility of all SanFranciscans. For more than adecade, under the leadershipof Treasurer José Cisneros,the OFE has engaged partnersinside and outside City Hall toequip San Franciscans withthe knowledge, skills andresources to strengthen theirfinancial health and well-being.At the same time, the OFE hasleveraged what has worked on theground to model what is possibleacross the country.

05Blacklisted: How ChexSystems Contributes to Systemic Financial ExclusionI.(FNIS) is one of the two most prominent accountscreening agencies. The other is Early WarningServices, a company that is jointly owned by Bankof America, BB&T, Capital One, JPMorgan Chase,and Wells Fargo.its learnings into practice, OFE also developedand implemented a local resolution process forfinancial coaching clients with ChexSystemsrecords, assisting clients with dispute resolutionand providing options for banking moving forward.Consumer advocates and banking expertshave long expressed concern about thesespecialty credit agencies and their use byfinancial institutions, including lack of accuracy,consistency, transparency, proportionality, anderror resolution. Unfortunately, there is limiteddata available on the prevalence of involuntaryaccount closures and ChexSystems records –which is troubling – but estimates have shown thatthe population affected is substantial. A ConsumerFinancial Protection Bureau (CFPB) study ofoverdraft programs estimated that six percent ofaccounts are closed involuntarily per year,v andthe most recent data OFE was able to identifysuggests that in 2005 up to 19 million people hadChexSystems records.viBased on local research, data and interviews,this report outlines the shortcomings associatedwith ChexSystems and other consumer reportingagencies and the impacts on vulnerable consumersin San Francisco. This report includes:Building on prior work around ChexSystems –including an excellent piece on account screeningagencies by the National Consumer Law Center andthe Cities for Financial Empowerment Fund – OFEsought to examine the issue at a local level in orderto create a resolution process for individuals withrecords and to generate suggestions for systemicreform. To understand the landscape, OFE firstsurveyed relevant stakeholders, such as financialinstitutions that participate in San Francisco’s localBank On program and ChexSystems itself, as wellas experts in the field. Next OFE researched localimpacts on financial coaching clients, reviewingChexSystems records obtained from 59 mostlyunbanked clients from October 2019 to August2020 and conducting in-depth interviews. To put B ackground on ChexSystems, including thecomponents of a ChexSystems report K ey findings on ChexSystems’s operations andits impacts on consumers using clients’ storiesand data Recommendations for reformThis report focuses on ChexSystems, becauseit is the most well-known consumer reportingagency, and financial coaches had access toreal-time ChexSystems data through ChexAdvisorEducational Reports, a new tool developed by theCredit Builders Alliance (CBA) in partnership withChexSystems. However, it is likely that the findingsin this report apply equally to other systems, suchas Early Warning Services.This report, and its recommendations, serve as areminder that creating safe and affordable productsand performing outreach and education aboutthose products may not be sufficient to increaseaccount access. To truly realize Bank On’s goal ofuniversal account coverage, the program mustfocus on systemic barriers to banking, includingChexSystems, which keep the most vulnerableconsumers from the financial mainstream.Background on ChexSystemsChexSystems Inc. (commonly referred to asChexSystems) is a consumer reporting agencythat tracks people’s banking histories. Financialinstitutions report information about customersto ChexSystems, and then ChexSystems compilesand reports that information back to financialinstitutions for a fee. Banks rely on this informationto screen prospective clients and, theoretically, toprevent account fraud. ChexSystems is governedby the Fair Credit Reporting Act and sharessimilarities with credit reporting agencies likeEquifax and Transunion. However, unlike traditionalcredit reporting agencies, ChexSystems reportsmostly negative information, such as involuntaryII.III.IV.

06Blacklisted: How ChexSystems Contributes to Systemic Financial ExclusionI.account closures. An estimated 80 percent ofall banks and credit unions use ChexSystems orother consumer reporting agencies such as EarlyWarning Services to decide whether to allow acustomer to open a checking or savingsaccount.viiReports compiled by ChexSystems includeinformation on customers’ banking history:involuntary account closures and inquiries.Involuntary account closures occur when a bankor credit union forcibly closes a client’s account,typically because of overdrafts or other “accountmismanagement.” Generally, records of accountclosures remain on a report for five years.viiiInvoluntary account closures are reported inChexSystems either as closures for (1) accountabuse or (2) suspected frauded depending on theseverity of the action and the account holder’smotivation. Banks have discretion to select thereason for account closure, and distinctionsaren’t clear (this issue is discussed in greaterdepth below). However, based on conversationswith ChexSystems and financial institutions, thefollowing rough definitions emerged: Account Abuse typically involves accountmismanagement and unpaid debt on anaccount without intention on the consumer’spart to misuse the account for financial orpersonal gain. Bank policies vary, but a recordfor account abuse will typically result in aconsumer being unable to open a new accountfor five years unless they pay their debt. S uspected Fraud typically involves suspicionof intentional misuse of an account forfinancial or personal gain. Since it is deemedmore severe, a record for suspected fraudtypically results in consumers being unable toopen a new account for five years regardless ofwhether the debt is repaid.The second component of a ChexSystems reportis inquiries. Inquiries signify that a consumer hasapplied for a financial product, like a bank accountor payday loan, though they do not represent actualuse of the product. Like account closures, inquiriesare separated into two categories: demand depositaccount (DDA) inquiries and non-demand depositaccount (non-DDA) inquiries. D emand deposit account (DDA) inquiriesinclude details on a consumer’s applicationsfor checking or savings accounts. N on-demand deposit account (non-DDA)inquiries include details on a consumer’sapplication for financial products outside oftraditional bank accounts, such as payday loans,installment loans, auto title loans, and more.The following figure outlines the components of aChexSystems report.What is on a ChexSystems Report?ChexSystems ReportAccountClosuresInquiriesAccount closure relatedto Suspected FraudAccount closure relatedto Account AbuseInquiry for Non-DemandDeposit Account (Non-DDA)Inquiry for DemandDeposit Account (DDA)II.III.IV.

07Blacklisted: How ChexSystems Contributes to Systemic Financial ExclusionI.II.III.IV.III. KEY ISSUES IDENTIFIEDWITH CHEXSYSTEMSWhile individual banks and credit unions utilizeChexSystems in a way they consider to be neutralto prevent fraud and manage risk, OFE’s researchrevealed systemic issues in both ChexSystems’design and implementation, resulting in significantconfusion and unfairness and ultimately undueexclusion for low-income consumers, and inparticular Black consumers. The four mainproblems uncovered through our research andinterview process include: Unclear, Unfair and Unequal Treatment individuals do not understand why they havea record and banks choose to close accountsand categorize those closures in an arbitrary,unfair, and unequal manner Ambiguous Impact of Inquiries – inquiriesshould not count against consumers andprevent consumers from opening accounts,but they appear to Impossible Resolution – it is nearly impossiblefor a consumer to resolve a ChexSystemsrecord via a dispute and resolution via debtrepayment varies from bank-to-bank withlimited information available to consumers Individual Impacts, Systemic Exclusion –ChexSystems records worsen individuals’financial vulnerabilities and have adisproportionate impact on Black consumersThe impacts of ChexSystems records are tangible,devastating, and widespread in San Franciscoand across the country. Individuals are faced withunintelligible and unfair outcomes and are unable toescape the system. Taken together, these individualcases result in a system that is mostly unknown,indecipherable, and inequitable, and results insystemic exclusion from the financial mainstreamfor the clients OFE is most dedicated to serving.Unclear, Unfair and Unequal TreatmentChexSystems is utilized within an almostcompletely opaque system, which allows banksto report and categorize involuntary accountclosures in arbitrary, unfair, and unequal ways. Inmost instances, individuals do not understand thatthey have a ChexSystems record or the reasonbehind that record. Banks are afforded almostcomplete discretion regarding involuntary accountclosures, including the rationale for the closureand the type of closure reported to ChexSystems.This discretion results in unfair outcomes, whereunwitting and good faith activity can be considered

08Blacklisted: How ChexSystems Contributes to Systemic Financial ExclusionI.and reported as suspected fraud or account abuse.Additionally, lack of definitional clarity results inunequal outcomes, where similar activity can becategorized as either suspected fraud or accountabuse, and financial institutions may use the debtowed as a proxy for severity of the offense.Unclear Records – People do not knowthey have ChexSystems recordsA primary issue OFE uncovered with ChexSystemsrecords is that there is little-to-no consumerunderstanding or awareness of the system orits implications. While 25 percent of financialcoaching clients whose records were reviewedhad an involuntary account closure reported toChexSystems, very few of these clients knew aboutthis record or understood how it could impactthem in the future. Once people learned about therecord from a financial coach, most were still notclear about the exact activity that resulted in theaccount closure and ChexSystems record. As oneclient, N.G., put it:““No I really never understood what [aChexSystems record] was. [My coach wasthe] first person that described it me – Iknew there was some sort of informationthat was going to be reported.”Unfair Treatment – Good faith activity canresult in ChexSystems recordsThough ChexSystems records ostensibly are usedto prevent fraud and root out malicious consumers,the majority of records result from repeatedoverdrafts or other unwitting or good faithbehavior. OFE’s research found numerous clientswho had their accounts closed due to repeatedoverdrafts or because they were victims of fraud oreven because of bank error.Most ChexSystems records result due to overdraftor non-sufficient fund transactions – which occurwhen a consumer does not have enough money intheir account to cover a transaction, but the bankprocesses it anyway, leading to a negative accountbalance – rather than fraudulent behavior. One 2008study found that 97.5 percent of account closuresreported to ChexSystems were due to overdrafts.ixOverdraft practices are highly profitable to banks– with banks earning an estimated 11 billion inoverdraft fees in 2019x – and banks’ own practicesand account structures can contribute to theprevalence of repeated overdrafts and involuntaryaccount closures. Closures triggered by overdraftare often the result of outstanding unpaid debt thatconsists mostly of fees, which dwarf the actualamounts withdrawn and represent profit ratherthan loss recovery for banks.xiThough a comprehensive discussion of overdraftis beyond the scope of this report, there arenumerous issues with the overdraft system:banks pressure consumers to open accounts withoverdraft enabled and then impose high fees;banks re-order transactions from high-to-low tomaximize fees (a practice now banned for banksregulated by the FDIC). Overdraft fees and resultingaccount closures can be devastating for clients,but they are also entirely preventable and withinbanks’ control. Many accounts, such as Bank Oncertified accounts, simply do not permit negativebalances. One client, S.T., who dealt with accountclosures due to overdrafts explained:““I didn’t put any money in [my account]and wasn’t really managing it well. Myaccount overdrafted and was closed aftermultiple purchases. The notification camelater. I told [the bank] that when I was inthe financial situation to pay them backI would and that’s what I did.” After theseincidents, S.T. made the decision not tobank for a while “because there’s alwayssomething that could go wrong.”Aside from repeated overdrafts, other good faithactivity can be labeled as account abuse and resultin involuntary account closure. Frequently thisoccurs when individuals are taken advantage of byacquaintances as happened to A.R.:II.III.IV.

09Blacklisted: How ChexSystems Contributes to Systemic Financial Exclusion“I.II.III.A.R. was a long-time member of a local credit union, having opened her accountmore than ten years prior when she was preparing to attend college. She loved thecredit union she banked with and valued the connection she built with branch staff:“That was important to me as Istarted learning and growing financially – building arelationship with my bank.” In November 2019, A.R.’s account was abruptly closedfor account abuse. She had been cashing checks for a family friend who didn’t haveher own bank account and wanted to avoid costly check cashing fees. A.R. cashedchecks for the family friend a few times before the friend provided A.R. with a badcheck. A.R. believed that the check had fully cleared, explaining that if she hadunderstood that the check did not clear she would have waited to withdraw thefunds. She realized she was a victim of fraud when the friend became unreachable byphone and moved out of California.This bad check left A.R. owing nearly 1,000 to the credit union. “I felt really sad afterthey closed my account When this situation happened, and this person put a wallbetween me and my bank, I was furious. I wasn’t trying to hurt the bank.”Looking back, A.R. wishes that she had more education on proper check usage andthat the credit union did a better job of clarifying when her checks had fully cleared,which might have prevented this closure from happening. At the time, A.R. wasunemployed and unable to pay back the negative account balance without sacrificingher basic needs. Once she became employed, the first thing she did was save to paythe credit union back because she wanted a clean record.Now, A.R. does not want a bank account, at least for the near future, becauseof everything that can go wrong. Simultaneously, she recognizes that bankingis essential in today’s day and age, “especially now during the pandemic andespecially now that some places are going paperless.”In the last example of unfairness, accountholderswho make no missteps at all can be saddled witha ChexSystems record due to bank error. SmartMoney Coaching client, R.S., had his accountclosed due to suspected fraud after a bank error.Ironically, this ‘suspected fraud’ label technicallyfits, because though he was completely absolved,the bank at one point incorrectly believed he hadcommitted fraud. This inaccuracy is particularlygalling because a label of suspected fraud impliesthe presence of criminal activity, whereas banksdo only limited (if any) due diligence to investigateand confirm the suspected fraud before reportingit to ChexSystems. R.S.’s story is notable andunique only because he was able to resolve hisChexSystems record with the assistance of afinancial coach and OFE staff.IV.

10Blacklisted: How ChexSystems Contributes to Systemic Financial Exclusion“I.II.III.R.S. was a loyal customer of his bank for more than 40 years. One day, he walked intohis local branch to send a routine wire transfer to his adopted children in Ghana anddiscovered his account was closed: “How I first found out was I went in to do a wiretransfer. The teller recognized me, and we started to do the transfer and she said I’msorry, [R.S.], but your account has been closed.”R.S. received no communication ahead of the closure and the teller was unable to tellhim why the account was closed. She told him there were no notes in their internalsystem. After two months of advocacy by R.S., his financial coach, and OFE staff, abank manager called R.S. to tell him that the bank would remove this incident fromhis ChexSystems record. It wasn’t until an additional month later that bank staff toldOFE that the account closure was because of a misapplied automatic deposit from astate agency outside of California, meaning the state agency accidentally sent fundsto the wrong person and tried to reach back into the account to remove the funds.R.S. was completely unaware of and uninvolved with the issue.After reaching out to branch staff many times in the span of two months, R.S.’sgreatest qualm was that branch staff were uninterested in hearing his side ofthe story or telling him what happened. Instead, he was immediately reported toChexSystems. “I should be worth more than that to the bank. I really feel violated andcouldn’t sleep at night. I was a victim, too.”R.S. says he hopes regulations will change so that banks allow a grace period forcustomers to contest an account closure. “If they want to suspend the account that’sone thing, but where’s the due process here?” he said. “This is not right, and thesystem is broken.”Unequal Treatment – Similar activityresults in different labels and outcomesUnlike the three national credit reporting agencies(Equifax, Transunion, and Experian) which userelatively standard definitions for credit issued,monthly payments and debt in delinquency,ChexSystems lacks clear definitions for “suspectedfraud” and “account abuse.” The system offerslimited guidance for how financial institutionsshould delineate between the two when categorizingthe reason for an involuntary account closure,though interviews with stakeholders, includingChexSystems itself, indicated that the differencearises based on the accountholder’s motivations andintentionality. This lack of clarity provides bankinginstitutions and even individual bank brancheswith nearly unfettered discretion in how to defineand apply these terms, leading to opaque internalpractices and industry-wide inconsistencies.For example, through interviews, OFE found thatsimilar or even identical customer banking activitycan be categorized in different ways, dependingIV.

11Blacklisted: How ChexSystems Contributes to Systemic Financial ExclusionI.on the financial institution involved. In the storiesbelow, two clients unknowingly deposited badchecks and withdrew the funds before the checkscleared. Both were victims of fraud. However, oneincident was labeled suspected fraud and the otherwas labeled account abuse. This inconsistencyis particularly troubling given that closures forsuspected fraud have harsher implications thanthose for account abuse.“R.K.’s credit union account was closed forsuspected fraud after she deposited andwithdrew funds from a bad check fromher employer. Her employer, a cateringcompany, wrote her a check for her workas they had many times before, but theyclosed their account before her creditunion could retrieve the funds.In contrast, when A.R. deposited a badcheck from a trusted acquaintance (seestory on p. 6), her involuntary accountclosure was categorized as account abuse.Without clear definitions, institutions mayuse irrelevant proxies, such as debt owed tothe institution, rather than the type of activityor motivation behind the activity to delineatebetween suspected fraud and account abuse. Onefinancial coach with over ten years’ experiencein the financial services industry noted that, intheir experience, once a client’s debt to a financialinstitution exceeds approximately 400 theaccount closure is typically labelled as suspectedfraud rather than account abuse.III.OFE’s limited review of clients’ ChexSystemsrecords corroborates this coach’s experience.Nine of the 11 clients flagged for account abuseowed debt of 400 or less and all 11 owed debtunder 600. In contrast, in accounts flagged forsuspected fraud, five out of the seven owed debtgreater than 400. There is no reason that thedetermination of suspected fraud should hinge onthe dollar value of the transaction. An individualcould owe 4,000 to a bank or credit union ingood faith if they were the victim of fraud or couldpurposefully and intentionally defraud a bank of 40.Using a debt threshold to define suspected fraudis fundamentally inaccurate and will necessarilyresult in inconsistent and unequal results.Offering Safe, Overdraft-Free AccountsShould Eliminate Need to UseChexSystemsIn addition to this unclear, unfair and unequaltreatment, there are certain situations whereChexSystems is simply unnecessary. Financialinstitutions assert that they use ChexSystemsand other account screening agencies in order tomitigate risk of fraud and loss. However, many banksand credit unions currently offer Bank On certifiedaccounts that meet national standards for safetyand affordability. These accounts are overdraftfree, meaning that they limit the occurrence of anynegative balances. This not only protects accountholders from overdraft fees but also protectsfinancial institutions from financial losses. Financialinstitutions should not be creating unnecessarybarriers where their own financial risk has alreadybeen hugely mitigated, if not eliminated.Ambiguous Impact of InquiriesAside from involuntary account closures,ChexSystems also collects and reports on inquiries.This inquiry information is purportedly neutralbut appears to be used at times to deny clients’accounts. As noted above, ChexSystems recordsconsumer inquiries for demand-deposit bankII.accounts (DDAs) at traditional financial institutionsas well as inquiries for loan products, like payday,installment, or auto title loans from fringe financialservices (non DDAs). Inquiries reflect interest inand applications for financial products not actualuse of these products. Many consumers shopIV.

12Blacklisted: How ChexSystems Contributes to Systemic Financial Exclusionaround, submitting multiple applications for paydayloans, and some may ultimately decide againstmoving forward with any loan.and are irrelevant to banking history and fraud.Similarly, no banks or credit unions interviewedfor this report indicated that inquiries play arole in decisions around bank account access.Nevertheless, OFE found instances, includingR.A.’s example below, where financial institutionsappeared to use past inquiries to deny a consumera bank account.ChexSystems staff stated that inquiries shouldbe viewed neutrally and should not be utilized forbanking decisions, which makes sense becauseinquiries reflect mere interest and not utilization“R.A. was denied an account with a local credit union because of inquiries intoinstallment and payday loans. R.A. made over 15 inquiries during December andJanuary, a time in which many low-income clients like R.A. experience extra financialhardship due to holiday spending. Her financial coach said, “[R.A. has] no othernegative entries on her report, yet a credit union rejected her checking accountapplication and said it was due to her ChexSystems report.” This account denial cameas a surprise to both R.A. and her financial coach because OFE has worked with manylocal banks and credit unions to understand their specific ChexSystems policies, butnone indicated that inquiries play a role in application decisions. Nevertheless, theseinquiries had an adverse effect on R.A.’s checking account application.Given the prevalence of fringe financial products,even limited account denials due to inquiries canhave significant impacts. Nationwide 12 millionpeople take out payday loans each year,xii and ofthe ChexSystems reports reviewed by OFE, over50 percent had at least one inquiry, meaning theycould be at risk for an account denial.

07 Blacklisted ow ChexSystems Contributes to Systemic Financial Exclusion While individual banks and credit unions utilize ChexSystems in a way they consider to be neutral to prevent fraud and manage risk, OFE's research revealed systemic issues in both ChexSystems' design and implementation, resulting in significant

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