[TheBank]

Our bank is looking at a second chance deposit account product where we offer a checking account with only a debit card, no checks, and the account is offered to customers that normally get denied from our Chex Systems criteria. We would select a range below our cut off with Chex Systems and for customers with adverse history, but within that range, we would offer this deposit account. There would be a monthly fee, which would be reduced with direct deposit, and no automated overdraft program would be allowed on this product. Does anyone offer something similar? and did you get CRA credit for this product?

[kmeade]

It depends on how your institution is evaluated. My bank’s CRA is evaluated by the Small Bank Evaluation method. We offer a second chance checking, but we have never included this for CRA credit. With the small servicer CRA, we list items that help meet the credit needs of our community. Based on other CRA evaluations, like intermediate small bank, this may be viewed as a community service targeted to low and moderate-income. This link to an FDIC’s CRA presentation https://www.fdic.gov/regulations/resources/director/presentations/cra.pdf may help.

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