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Board of Governors of the Federal Reserve System

Federal Deposit Insurance Corporation

Financial Crimes Enforcement Network

National Credit Union Administration 

Office of the Comptroller of the Currency

February 24, 2015

Citations updated as of November 9, 2017

Guidance to Encourage Financial Institutions’ Youth Savings Programs and Address 

Related Frequently Asked Questions

The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance 

Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the 

Comptroller of the Currency (OCC), as members of the Financial Literacy and Education 

Commission (FLEC), together with the Financial Crimes Enforcement Network (FinCEN) of the 

U.S. Department of the Treasury, are issuing guidance regarding youth savings programs. The 

issuance of this document is also supported by the agencies that serve as the FLEC Chair (the 

U.S. Department of the Treasury) and Vice Chair (the Consumer Financial Protection Bureau).

The purpose of the guidance is to encourage financial institutions1 to develop and implement 

programs to expand the financial capability of youth and build opportunities for financial 

inclusion for more families. The guidance also addresses frequently asked questions that may 

arise as financial institutions collaborate with schools, local and state governments, non-profits, 

or corporate entities to facilitate youth savings and financial education programs. Such efforts 

are consistent with the FLEC’s National Strategy for Financial Literacy to advance the 

expansion of financial capability among America’s youth and to increase their opportunities to 

save.

2

Background

Throughout the country, various financial institutions collaborate with elementary, middle, and 

high school administrators, and, in some cases, with government, non-profit, or private entity 

partners to administer youth savings and financial education programs. The youth savings 

programs are often structured as in-school credit union or bank programs that offer students basic 

savings accounts. They also may include more complex asset-building accounts and school 

district-wide programs that offer universal savings accounts to large numbers of children or nonschool based models administered by state and local governments and non-profit agencies. 

Research indicates that youth savings programs may be effective in helping improve long-term 

financial and educational outcomes, such as completing college. 

 1 This guidance uses the term “financial institution” or “institution” to refer to all federally insured depository 

institutions. 

2 “Promoting Financial Success in the United States: National Strategy for Financial Literacy 2011,” available at

http://www.treasury.gov/resource-center/financial-education/Documents/NationalStrategyBook_12310%20(2).pdf.
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Youth savings programs are generally linked to a diverse array of financial education efforts,

including personal financial management, banking operations, or both. They are intended to help 

students understand the value of saving for the future by opening and managing savings 

accounts. These savings accounts generally have very low minimum balance requirements and

low or no monthly maintenance fees. Material account terms and conditions are also explained 

in an age-appropriate manner.

Financial institutions and others involved with youth savings programs indicate that there is 

some uncertainty about several legal and regulatory considerations relating to these programs

and that this uncertainty may cause some institutions to be reluctant to develop youth savings 

initiatives. This guidance provides answers to common questions received regarding youth 

savings programs. This document does not create new regulatory agency policy or industry 

expectations.

Banking Activity Questions

1. Are there restrictions on minors opening savings accounts? How old must a person be to 

open a savings account without a parent or guardian serving as the custodian or coowner on the account?

No federal law prohibits minors from opening savings accounts. Rather, a deposit 

account relationship is based on a contract governed by state law. In general, minors are 

deemed to not have the legal capacity to enter into a contract, including opening an 

account at a financial institution, meaning that a contract with a minor is potentially 

“voidable.” However, some states specifically allow a minor to open a savings account. 

For example, the State of Washington permits a minor to enter into a valid and 

enforceable contract for a deposit account with a financial institution.3 States also have 

different legal definitions of “minor.”

Whether it is legally permissible for an institution to open an account for a minor without 

requiring a responsible adult to be the custodian or co-owner is a determination that a

financial institution should make in consultation with legal counsel.

2. Can a minor with a custodial account be issued an automated teller machine (ATM) or 

debit card? 

The Uniform Transfers to Minors Act or Uniform Gifts to Minors Act of each state 

governs custodial accounts for minors. As a general matter for custodial accounts, a 

custodian manages the funds in the account on behalf of a minor, meaning the minor 

would not be able to withdraw funds without the custodian’s approval. Therefore, a 

minor with a custodial account should not be provided with an ATM or debit card that 

permits withdrawals.

 3 See Rev. Code of Wash. 30.22.070. 
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3. Do consumer protection laws and regulations apply to accounts held by or for the benefit 

of minors? 

As with other deposit accounts, various federal and state consumer financial protection 

laws and regulations apply to youth savings accounts. Applicable federal consumer 

financial protection laws and regulations include, but are not limited to, the Children’s

Online Privacy Protection Act (Children’s Online Privacy Protection Rule),4 the 

Electronic Fund Transfer Act (Regulation E),5 the Expedited Funds Availability Act 

(Regulation CC),6 the Truth in Savings Act (Regulation DD),7 and prohibitions against 

unfair or deceptive acts or practices.8 

For example, the Truth in Savings Act (Regulation DD) requires financial institutions to 

comply with certain requirements when advertising deposit accounts, provide consumer 

account holders with particular written information about account terms, provide certain 

fee and other information in periodic statements sent to consumers, and use specific 

methods to determine the account balance upon which interest is calculated.

4. Can banks and savings associations receive consideration under the Community 

Reinvestment Act (CRA) for developing and implementing youth savings programs? 

Banks and savings associations may receive CRA consideration if they provide youth 

savings and financial education programs targeted primarily to low- and moderateincome students. The CRA’s definition of “community development” includes 

“community services targeted to low- or moderate-income individuals.”9

 To the extent 

that a financial institution’s youth savings program has a primary purpose of community 

development, the program will receive CRA consideration as a community development 

service.10 In addition, the interagency CRA guidance provides examples of community 

development services that include establishing school savings programs or developing or 

teaching financial education or literacy curricula for low- or moderate-income 

individuals.11 Financial institutions are also reminded that the interagency CRA guidance 

provides examples illustrating how financial institutions can determine whether 

community services are provided to low- and moderate-income individuals. One such 

example is when a community service is provided to students or their families from a 

 4 Children's Online Privacy Protection Act of 1998, 15 U.S.C. 6501 et seq.; 16 CFR Part 312 (Children’s Online 

Privacy Protection Rule). 5 Electronic Fund Transfer Act, 15 U.S.C. 1693 et seq.; 12 CFR Part 1005 (Regulation E). 6 Expedited Funds Availability Act, 12 U.S.C. 4001 et seq.; 12 CFR Part 229 (Regulation CC). 7 Truth in Savings Act, 12 U.S.C. 4301 et seq.; 12 CFR Part 1030 (Regulation DD). 8 Federal Trade Commission Act, Section 5, 15 U.S.C. 45(a). 9 See 12 CFR 25.12(g)(2), 195.12(g)(2), 228.12(g)(2), 345.12(g)(2). 10 See Interagency Questions and Answers Regarding Community Reinvestment __.12(h) – 8, 81 Fed. Reg. 48506, 

48530 (July 25, 2016), available at https://www.gpo.gov/fdsys/pkg/FR-2016-07-25/pdf/2016-16693.pdf 

(“interagency CRA guidance”). See also Interagency Questions and Answers Regarding Community Reinvestment, 

__.12(i) – 3, 81 Fed. Reg. at 48530-31. 11 See Interagency Questions and Answers Regarding Community Reinvestment __.12(i) – 3, 81 Fed. Reg. at 48530-

31.
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school at which the majority of students qualify for free or reduced-price meals under the 

U.S. Department of Agriculture’s National School Lunch Program.12

5. Is a financial institution required to file a branch application when it partners with a 

school to offer a youth savings program?

Requirements for financial institutions to file a branch application in connection with a 

youth savings program vary by regulatory agency. Generally, a branch application 

might not be required if the primary purpose of the youth savings program is financial 

education designed to teach students the principles of personal financial management, 

banking operations, and saving for the future, and the program is not designed for the 

purpose of profit-making. Agency-specific requirements are summarized below, and 

financial institutions participating in such programs should contact their respective 

regulators to determine whether such activity requires a branch application.

FDIC-Supervised Institutions

FDIC regulations permit a state nonmember bank to provide banking services (such as 

opening or maintaining savings accounts) in schools without filing a branch application 

or obtaining prior approval from the FDIC if: 

• Such service or services are provided on school premises, or a facility used by the 

school;

• Such service or services are provided at the discretion of the school;

• The principal purpose of each program is financial education. For example, the 

principal purpose of a program would be considered to be financial education if 

the program is designed to teach students the principles of personal financial 

management, banking operations, or the benefits of saving for the future, and is 

not designed for the purpose of profit-making; and

• Each program is conducted in a manner that is consistent with safe and sound 

banking practices and complies with applicable law.13

Applicable state law and the appropriate state supervisory authority determine branch 

application requirements, if any, for state savings associations.

FRB-Supervised Institutions

The FRB has not issued branch application policies or regulations specifically applicable 

to youth savings programs. FRB branch application information is available on the 

FRB’s website.

14 

 12 See Interagency Questions and Answers Regarding Community Reinvestment __.12(g)(2) – 1, 81 Fed. Reg. 

48526. 13 See 12 CFR 303.46 and 73 FR 35337 (June 23, 2008). 14 See https://www.federalreserve.gov/supervisionreg/afi/afi.htm. See also 12 CFR 208.6. 
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NCUA-Supervised Institutions

Applicable state law and the appropriate state supervisory authority determine branch 

application requirements, if any, for state-chartered credit unions. The Federal Credit 

Union Act and NCUA regulations do not establish any branch application requirements 

for federal credit unions. The Federal Credit Union Act does provide that federal credit 

unions were organized for, among other things, promoting thrift among members.15 This 

provision is the basis for these credit unions’ youth savings programs. In addition, since 

2009, NCUA’s 5300 Call Report has collected information about credit unions’ financial 

literacy programs, including in-school branches promoting youth financial literacy. 

OCC-Supervised Institutions 

National banks that seek to set up school-based youth savings programs in nonbank 

branch settings must comply with 12 CFR 7.1021. National banks that have schoolbased youth savings programs that do not meet the conditions in 12 CFR 7.1021 must 

submit branch applications to the OCC. 

National banks may participate in financial literacy programs, such as school-based youth

savings programs, on the premises of, or at a facility used by, a school.

16 A branch 

application is not required and the school premises or facility would not be considered a

branch when:

• The bank does not establish and operate the school premises or facility on which 

the financial literacy program is conducted. 

• Bank employees work at the site only to participate in the program.

• No services are provided to the general public.

• The principal purpose of the financial literacy program is educational. For 

example, a program is educational if it is designed to teach students the principles 

of personal economics or the benefits of saving for the future and is not designed 

for the purpose of profit-making.17 

Similar rules are applicable to federal savings associations.

18 Generally, a branch 

application is not required and a federal savings association’s school-based financial 

education program would not be considered a branch of the savings association as long as 

the program meets the following criteria:

• The program is conducted on school premises and is not open to the general 

public. 

 15 See 12 U.S.C. 1752(1). 16 See OCC Interpretive Letter No. 839, November 1998, available at http://www.occ.gov/static/interpretations-andprecedents/nov98/int839.pdf; OCC Advisory Letter 2001-1, “Financial Literacy” (January 16, 2001), available at

http://www.occ.gov/static/news-issuances/memos-advisory-letters/2001/advisory-letter-2001-1.pdf; and 12 CFR

7.1021 [66 Fed. Reg. 34791 (July 2001)]. 17 See “School-Based Bank Savings Programs: Bringing Financial Education to Students,” OCC Community 

Developments Insights report (April 2009), available at http://www.occ.gov/topics/communityaffairs/publications/insights/insights-school-based-bank-savings-programs.pdf. 18 See Office of Thrift Supervision Opinion Letter, Proposal to Create a School Partnership Program (November 20, 

1992), available at http://www.occ.gov/topics/community-affairs/resource-directories/financial-literacy/opinionletter.pdf.
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• Association employees would not be on the school’s premises once the program is 

commenced.

• The association does not establish an office that is owned, leased, or operated by 

the association in connection with the program.

• The services provided on the school’s premises are limited.

• Student accounts would not be established until applications and funds are 

received and accepted at a home or branch office of the association.

• The association would not be liable for any theft, loss, or embezzlement until 

funds are deposited and accepted at a home or branch office of the association.

Customer Identification Program (CIP) Questions

6. Does the CIP rule prohibit a minor from opening an account? 

No. If a minor opens a savings account, the minor is the financial institution’s customer. 

For example, where a financial institution sends its employees to a school so that students 

may open savings accounts by themselves without the involvement of a parent or 

guardian as part of a program to promote financial education, the student opening an 

account is the financial institution’s customer. 

However, if a parent, guardian, or third party19 opens an account on behalf of a minor, the 

financial institution’s customer is the parent, guardian, or third party. The CIP rule states 

that the financial institution’s “customer” is the person who opens the account for a

person who lacks legal capacity, such as a minor. 

See 31 CFR 1020.100(c)(1)(i-ii)20 and Interagency Interpretive Guidance on Customer 

Identification Program Requirements under Section 326 of the USA PATRIOT Act, 2005 

FAQs: Final CIP Rule, Definition of “customer,” FAQ #6.

21

7. What requirements of the CIP rule apply to a financial institution that opens an account 

on behalf of a customer, including a minor, such as through a youth savings program?

Section 326 of the USA PATRIOT Act requires each financial institution to establish,

maintain, and implement a written CIP appropriate for its size and type of business. As 

with other accounts, if a financial institution opens an account for a minor, the CIP must 

include risk-based procedures for: (1) verifying the identity of any customer seeking to 

open an account, to the extent reasonable and practicable; (2) maintaining records of the 

 19 See Question 10. 20 In March 2010, FinCEN transferred its regulations from 31 CFR Part 103 to 31 CFR Chapter X. References to 

FinCEN regulations in this guidance are cited in their current format, while regulations referenced in the CIP FAQs 

use the format in existence at the time the FAQs were first published. FinCEN’s website has a tool for the purpose 

of converting the old citation format to the new one, and vice versa. 21 See https://www.fincen.gov/sites/default/files/shared/faqsfinalciprule.pdf.
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information used to verify the customer's identity; (3) determining whether the customer

appears on any lists of known or suspected terrorists or terrorist organizations issued by 

any government agency; and (4) providing customers with adequate notice that the 

financial institution is requesting information to verify their identities.

22

8. Based on the CIP rule, what information must a financial institution collect from a 

customer when opening an account, including for a minor? 

Under the CIP rule, a financial institution must obtain, at a minimum, the following 

information from the customer prior to opening an account:

23

• name; 

• date of birth; 

• address; and 

• identification number. 

An address for an individual can be a residential or business street address or, if the 

individual does not have such an address, an Army Post Office (APO) or Fleet Post 

Office (FPO) box number or the residential or business street address of next of kin or of 

another contact individual.

24

The CIP rule provides that the identification number for a U.S. person shall be a taxpayer 

identification number. For a non-U.S. person, the identification number shall be one or 

more of the following: a taxpayer identification number; passport number and country of 

issuance; alien identification card number; or number and country of issuance of any 

other unexpired government-issued document evidencing nationality or residence and 

bearing a photograph or similar safeguard.25

9. How can a financial institution verify the identity of a minor in order to satisfy the CIP 

rule when the minor is the customer?

Since verification procedures are risk-based, institutions may use reasonable 

documentary or non-documentary methods to verify a minor’s identity. The procedures 

must describe when the financial institution will use documents, non-documentary 

methods, or a combination of both. The financial institution’s CIP must contain 

procedures for verifying the identity of the minor within a reasonable time after the 

account is opened. 

For a financial institution relying on documents to verify a minor’s identity, the CIP must 

include procedures that set forth the documents that the financial institution will use. For 

 22 See 31 CFR 1020.220(a). 23 See 31 CFR 1020.220(a)(2)(i). 24 See 31 CFR 1020.220(a)(2)(i)(A)(3)(i)-(ii). 25 See 31 CFR 1020.220(a)(2)(i)(A)(4).
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example, the financial institution might verify a minor’s identity using a student 

identification card.

For a financial institution relying on non-documentary methods, the CIP must contain 

procedures that describe the non-documentary methods that the financial institution will 

use to verify a minor’s identity. These methods may include contacting a customer or 

independently verifying the minor’s identity through the comparison of information 

provided by the minor with information obtained from a consumer reporting agency, 

public database, or other source. For example, the financial institution might verify a 

minor’s identity in an in-school program by having a teacher confirm the minor’s

identity. 

See 31 CFR 1020.220(a)(2)(ii)(A)-(B) and Interagency Interpretive Guidance on 

Customer Identification Program Requirements under Section 326 of the USA PATRIOT 

Act, 2005 FAQs: Final CIP Rule, Definition of “customer,” FAQ #6.

Third-Party Deposit Relationships

10. What are the CIP requirements for customer verification for a financial institution when

a third-party (such as a school district or other governmental unit, educational 

institution, non-profit organization, or corporate sponsor) opens a trust, custodial, or 

other administrative account at a financial institution to maintain and administer assets 

for multiple minors?

There are circumstances where a party may create a master savings account with subaccounts for various minors to save for a restricted purpose (such as higher education). 

For purposes of the CIP rule, generally, the customer is the “person” (individual, 

corporation, partnership, or trust) who opens a new account for another individual who 

lacks legal capacity, such as a minor.

26

In these settings, the “customer” is the trust, regardless of whether the financial 

institution is the trustee for the trust. A financial institution will not be required to look 

through trust, escrow, or similar accounts to verify the identities of beneficiaries of the 

accountholder. Instead, the financial institution will only be required to verify the 

identity of the named accountholder by obtaining, at a minimum, the accountholder’s

name, address,

27 and identification number (see response to Question 8 above). 

Moreover, the CIP rule also provides that, based on the financial institution’s risk 

assessment of a new account opened by a customer that is not an individual, the 

institution may need to obtain information about individuals with authority or control 

over such an account, including signatories, in order to verify the customer’s identity. 

 26 See 31 CFR 1020.100(c)(1). 27 An address for a person other than an individual is defined as a principal place of business, local office, or other 

physical location. See 31 CFR 1020.220(a)(2)(i)(A)(3)(iii). 
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This verification method applies only when the institution cannot verify the customer's 

true identity using documentary and non-documentary verification methods.

28 

See 31 CFR 1020.220(a)(2)(ii) and Interagency Interpretive Guidance on Customer 

Identification Program Requirements under Section 326 of the USA PATRIOT Act, 2005 

FAQs: Final CIP Rule, Definition of “customer,” FAQ #9.

In addition, in circumstances involving accounts for minors established by a custodian, 

financial institutions should be aware of the requirements for the individual deposits to be 

eligible for deposit insurance coverage by the FDIC29 or NCUA.

30

 28 See 31 CFR 1020.220(a)(2)(ii)(C). 29 12 CFR 330.5. 30 12 CFR 745.
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Other Relevant Resources

• Consumer Financial Protection Bureau (CFPB):

o Help children build money skills—information for parents and caregivers of 

children pre-kindergarten through young adulthood:

http://www.consumerfinance.gov/parents/

o Pay for college—consumers can get help to make informed financial decisions 

about how to pay for college:

http://www.consumerfinance.gov/paying-for-college/

• FinCEN:

o Interagency Guidance on CIP Requirements 2005 FAQs: Final CIP Rule:

https://www.fincen.gov/resources/statutes-regulations/guidance/interagencyinterpretive-guidance-customer-identification

o General FinCEN Regulation Guidance:

https://www.fincen.gov/resources/statutes-regulations

o Questions on the CIP rules can also be directed to the FinCEN Resource Center at 

(800) 767-2825.

• Federal Financial Institutions Examination Council (FFIEC):

o Interagency Questions and Answers Regarding Community Reinvestment: 

http://www.ffiec.gov/cra/qnadoc.htm

• FLEC:

o https://www.mymoney.gov is a resource to identify other financial education 

resources from more than 20 federal agencies.

o National Strategy for Financial Literacy (2011), available at 

http://www.treasury.gov/resource-center/financialeducation/Documents/NationalStrategyBook_12310%20(2).pdf.

• FDIC: 

o Youth Financial Education Letter, FIL-80-2010, November 17, 2010: 

https://www.fdic.gov/news/news/financial/2010/fil10080.html

o Youth Banking Resource Center:

https://www.fdic.gov/youthsavings

o Teacher Online Resource Center:

https://www.fdic.gov/teachers

o Money Smart Financial Education program:

https://www.fdic.gov/moneysmart

• FRB:

o Financial Literacy Resources:

http://www.federalreserveeducation.org/

o Branch Application Information (12 CFR 208.6):

https://www.ecfr.gov/cgi-bin/text-idx?SID=a8fbfbc9595e05e626b7e571 

f282f21c&mc=true&node=se12.2.208_16&rgn=div8
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• NCUA:

o Financial Literacy and Resources for credit unions and the consumers they serve:

https://www.ncua.gov/consumers/Pages/financial-literacy-resources.aspx

o NCUA Webinar—Financial Literacy: Putting Your Mission Into Action:

https://www.youtube.com/watch?v=BLMI7iZ6wGk

o MyCreditUnion.gov—Credit Unions in Schools:

https://www.mycreditunion.gov/Pages/credit-unions-in-schools.aspx

o An Early Investment in Personal Finance Education Pays A Lifetime of 

Dividends:

http://www.ncuareport.org/ncuareport/april_2014?pg=11#pg11

• OCC: 

o “School-Based Bank Savings Programs: Bringing Financial Education to 

Students,” OCC’s Community Development Insights report:

http://www.occ.gov/topics/community-affairs/publications/insights/insightsschool-based-bank-savings-programs.pdf

o OCC Interpretive Letter No. 839, November 1998: 

http://www.occ.gov/static/interpretations-and-precedents/nov98/int839.pdf 

o OCC Advisory Letter 2001-1, “Financial Literacy” (January 16, 2001): 

http://www.occ.gov/static/news-issuances/memos-advisory-letters/2001/advisoryletter-2001-1.pdf

o 12 CFR 7.1021 [66 FR 34791 (July 2001)]: http://www.ecfr.gov/cgi-bin/textidx?SID=70966f64398a9aa52c0695f8deef7de2&node=12:1.0.1.1.7.1.25.20&rgn=

div8]

o Office of Thrift Supervision Opinion Letter, Proposal to Create a School 

Partnership Program (November 20, 1992):

http://www.occ.gov/topics/community-affairs/resource-directories/financialliteracy/opinion-letter.pdf

o Other resources can be found on the OCC’s Financial Literacy Resource 

Directory:

http://www.occ.gov/topics/community-affairs/resource-directories/financialliteracy/index-financial-literacy.html

• Treasury:

o Financial Education and Account Access Among Elementary Students: Assessing 

Financial Capability Outcomes Pilot. Both the full report and research brief are 

available through http://www.treasury.gov/resource-center/financialeducation/Pages/default.aspx.