2011 FDIC

Survey of Banks’ 

Efforts to Serve 

the Unbanked 

and Underbanked

December 2012

Federal Deposit 

Insurance Corporation

Executive Summary
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  

Members of the FDIC Unbanked/Underbanked Survey Study Group

Division of Depositor and Consumer Protection: Susan Burhouse, Sarah Campbell, 

 Timothy Critchfield, Ross Dierdorff, Keith Ernst, Ryan Goodstein, Yazmin Osaki, 

 Luke Reynolds, and Sherrie Rhine.

Division of Insurance and Research: David Chapman, Eric Robbins, and Katherine Samolyk.

Legal Division: Leneta Gregorie.

Lead Authors

Sherrie L.W. Rhine and Eric Robbins.

Lead Statistical Analysts and Advisors

David Chapman, Ryan Goodstein, and Chris MacColl.

Contributors: 

Karyen Chu, Anirudh Sarna, Masseh Tahiry, Shannon Williams, Kathy Zeidler.
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  • 

I. Executive Summary

This report presents the results of the 2011 FDIC Survey 

of Banks’ Efforts to Serve the Unbanked and 

Underbanked (Bank Survey). As mandated by Federal 

law, the FDIC surveys insured depository institutions 

every two years to assess their efforts to bring individuals 

and families who have rarely, if ever, held a checking or a 

savings account at an insured depository institution, into 

the financial mainstream.1

Accordingly, the primary purpose of the Bank Survey is to 

understand the efforts being undertaken by the retail 

banking industry to provide financial products and 

services to unbanked and underbanked consumers. The 

findings help inform financial institutions, policymakers, 

community organizations, and other stakeholders interested in expanding financial products and services to 

unbanked and underbanked consumers. 

The Bank Survey was voluntary and consisted of an 

Internet-based questionnaire administered to a nationally 

representative random stratified sample of 707 retail bank 

headquarters, with 567 banks (80 percent) responding. 

Through the survey design, banks are grouped into one of 

three asset size categories: the largest 25 banks (with assets 

greater than $38 billion), the smallest institutions (with 

assets less than $1 billion), and midsize banks (with assets 

between $1 billion and $38 billion). Data was collected 

from November 2011 through February 2012. 

The survey questions identify the extent to which insured 

depository institutions offered basic and auxiliary financial 

products and services, developed and marketed products, 

used retail strategies, and provided financial education and 

outreach activities to expand financial services to 

unbanked and underbanked consumers. The survey also 

asks about challenges and obstacles that might affect the 

ability of banks to offer financial services to the 

underserved. 

Key Findings 

Product Development, Marketing, and Advertising

Four out of ten banks develop products and services for 

underserved consumers. Developing and actively marketing specialized products, services, or programs that are 

customized to meet the needs of unbanked and underbanked consumers are important steps banks can take to 

encourage full participation in the financial mainstream. 

1 The Survey was mandated by Section 7 of the Federal Deposit Insurance Reform Conforming Amendments Act of 2005. The FDIC retained 

Gallup, Inc. to help administer the survey of banks. Gallup, Inc. collected 

the survey results and reported findings which did not have bank-identifier information to the FDIC.

Almost 43 percent of banks were actively involved in 

developing products and services for underserved 

consumers. 

Banks see community partnerships as an important 

strategy to reach underserved consumers. When asked to 

identify both the most effective marketing channels for 

reaching these consumers and retail strategies used, banks 

tended to identify community outreach collaborations and 

automated telephone banking, respectively. In addition, 

about half of banks reported using community partnerships 

specifically to promote accounts to underserved consumers.

Other, 10

Community 

outreach 

collaborations, 39

TV or radio 

advertising, 6

Print advertising, 29

Email or social media 

marketing, 1

Direct mail, 8

Billboard 

advertising, 6

Note: Proportions are calculated based on respondents that actively marketed to the unbanked and 

underbanked and that answered the question about most effective marketing channels.

Figure 1.1: Most Effective Marketing Channels (Percent)

Basic Financial Products and Services

Almost half of all banks required an initial deposit of 

$100 or more to open a basic checking account. On the 

most basic or entry-level checking account, 6 percent of 

banks required a minimum opening balance of more than 

Non-Traditional Location

Off-Premise ATMs in Retail 

Establishments

Non-Traditional Branch

Format/Design

Extended Banking Hours

Multilingual Staff Available

Online (Internet) Banking

Mobile (Cell Phone) 

Banking

Automated (IVR) 

Telephone Banking

Other

Note: Proportions are calculated based on respondents that answered the questions about retail strategies. 

Figures may not reconcile to 100 due to rounding.

Figure 1.2: Retail Strategies Used to Make the

Bank More Welcoming or Convenient (Percent)

10

40

38

37

43

8

28

62

30

0 10 20 30 40 50 60 70 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  • 

$100 and 42 percent required precisely $100 on accounts 

without direct deposit. Forty-eight percent of banks 

required $50 or less to open such an account. 

Nearly two-thirds of banks charged no monthly maintenance fees on basic checking accounts, though one in 

five charged more than $3 per month on accounts without direct deposit. Regardless of whether a bank had 

products and services that specifically targeted unbanked 

and underbanked consumers, respondents were asked to 

indicate the features and fees for their most basic or entrylevel checking accounts. Sixty-five percent of banks 

charged no monthly maintenance fees, 10 percent charged 

fees of between $1 and $3, and 22 percent charged fees in 

excess of $3. On checking accounts with direct deposit, 72 

percent of banks charged no maintenance fee. Among 

those that charged a fee, the median monthly amount was 

$5 for accounts with and without direct deposit. 

Note: : Proportions are calculated based on all banks.

Figure 1.4: Monthly Maintenance Fees for Basic 

Entry-Level Checking Accounts (Percent)

65

10

22

72

8

17

0

10

20

30

40

50

60

70

80

$0 $1 to $3 >$3 $0 $1 to $3 >$3

Monthly Maintenance Fee

without Direct Deposit

Monthly Maintenance Fee

with Direct Deposit

Percentage of Banks

The median charge for overdraft payments and on 

checks and other items rejected for nonsufficient funds 

were both $28. In the large majority of cases, banks 

charged the same amount for overdraft payments or when 

items were rejected due to nonsufficient funds. 

Two out of ten banks offered a “second chance” account 

to individuals that do not qualify for a basic checking 

account. The survey found that 21 percent of banks 

offered a “Stepping Stone” or “Second Chance” account 

to individuals not qualified for conventional accounts. 

Few banks offered a card-based “checkless” checking 

account as their most basic, entry-level account. Among 

all banks, 21 percent offered electronic (card-based) 

accounts as their most basic transaction account product. 

Fewer—less than 1 percent of banks—offered a strictly 

card-based, electronic account (i.e., an account that does 

not allow at least some paper checks to be written). 

Banks required a median minimum initial deposit of 

$100 to open a basic savings account, though most 

banks did not charge a monthly maintenance fee if minimum average balance requirements were met. The 

median minimum average balance to avoid a monthly fee 

was $100. If the minimum average balance requirement 

was not met, the median monthly maintenance fee was 

$2.50.

More than eight out of ten banks offered specialty 

savings products, such as youth savings accounts. A 

majority of banks (87 percent) offered at least one of the 

following specialty savings products: Individual 

Development Accounts (IDAs), specialized savings clubs, 

workplace-based savings, or youth (minor) savings 

accounts. Youth accounts dominated, with 82 percent of 

financial institutions offering this savings product. Fortyone percent of banks offered specialized savings clubs, 

while 9 percent of banks offered workplace-based savings 

accounts and close to 4 percent offered IDAs. 

Most banks accepted non-traditional forms of identification to open accounts. A majority of banks accepted a 

non-US passport or some other nontraditional form of 

identification (ID) from prospective customers. Among 

respondents, 58 percent of banks accepted a non-US passport, 40 percent accepted ID from a foreign consulate, and 

73 percent accepted an Individual Taxpayer ID Number 

(ITIN) as an alternative to a Social Security Number at 

account opening. 

Auxiliary Products 

Most banks offered check-cashing, bank checks, money 

orders, and remittances for existing accountholders, but 

not for others. The most commonly offered auxiliary 

products to both basic accountholders and noncustomers 

were payroll check cashing (71 percent for accountholders 

and 47 percent for noncustomers), bank or other official 

checks (86 percent for accountholders and 35 percent for 

noncustomers), and money orders (68 percent for accountholders and 33 percent for noncustomers). Compared to 

these commonly offered auxiliary products, domestic and 

Note: Proportions are calculated based on all banks where balance requirements are for accounts where 

paycheck direct deposit is not in use. No respondents reported a minimum opening balance of between 

$50 and $100.

Figure 1.3: Minimum Opening Balance Requirement (Percent)

15 16 17

42

6

0

5

10

15

20

25

30

35

40

45

Percentage of Banks

$0 $1-$49 $50 $100 >$100
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  • 

international remittances were offered less frequently. 

Sixty-eight percent of banks offered domestic remittances 

to basic accountholders and 57 percent offered international remittances to basic accountholders, but only 

slightly more than 11 percent offered domestic and 9 

percent offered international remittances to 

noncustomers. 

Note: Proportions are calculated based on respondents that answered the question. 

71 68 

86 

22 

57 

68 

47 

33 35 

9 9 11 

0 

10 

20 

30 

40 

50 

60 

70 

80 

90 

100 

Cashing Payroll 

Checks 

Money Orders Bank or Other 

Ofcial Checks 

In-Person 

Third-Party 

Bill Pay 

International 

Remittances 

Domestic 

Remittances 

Percentage of Banks 

Basic/Entry-Level Accountholders Noncustomers 

Figure 1.5: Offering Auxiliary Products to Basic 

Accountholders and Noncustomers (Percent)

Eight out of ten banks offered small (under $2,500) 

unsecured personal loans. The survey finds that 88 

percent of all banks offered unsecured personal loans. 

Among these banks, 43 percent offered unsecured 

personal loans with no minimum loan amount and an 

additional 53 percent offered unsecured personal loans 

with a minimum loan amount of $2,500 or less, which are 

referred to collectively as small dollar loans in this report. 

Note: Proportions are calculated based on respondents that answered the question and also made 

unsecured personal loans.

Figure 1.6: Minimum Loan Amount of 

Unsecured Personal Loans (Percent)

43 

53 

4 

0 

10 

20 

30 

40 

50 

60 

No Minimum $1 to $2,500 More than $2,500 

Percentage of Banks 

Banks offering small dollar loans tended to do so with 

repayment terms of 90 days or more, with annualized 

rates of 36 percent or less, and with loan approvals in 

less than 24 hours. Among banks that offered small 

dollar loans, a large majority offered loans with a repayment period of 90 days or more, an annual percentage rate 

(APR) of 36 percent or less, and streamlined underwriting 

to make a loan decision within 24 hours. Eighty-one 

percent of banks with small dollar loans indicated that the 

associated repayment period was 90 days or more. The 

APR (including upfront fees) was reported to be below 36 

percent at nearly 89 percent of these banks. In addition, 

most banks could approve a small, unsecured loan in less 

than 24 hours. 

Figure 1.7: Features of Small Dollar Loans (Percent) 

Note: Proportions are calculated based on respondents that answered the question and where banks also 

made unsecured personal loans of $2,500 or less.

81 

89 

92 

74 

76 

78 

80 

82 

84 

86 

88 

90 

92 

94 

Repayment Period 90+ Days APR of 36 Percent or Less Streamlined Application 

Process 

Percentage of Banks 

Financial Education and Outreach

Eight out of ten banks reported providing free counseling 

to underserved consumers. The survey asked banks if 

they provided financial education and outreach activities, 

including teaching basic financial education, funding 

community partners, providing technical expertise, and 

offering free counseling. Free counseling was the most 

frequently used and most highly rated activity targeted to 

unbanked and underbanked consumers. Overall, 81 

percent of banks said they offered free counseling to 

underserved consumers and 58 percent rated this activity 

as very effective or effective. The most common locations 

were K-12 schools, with 74 percent of banks providing 

financial education and outreach activities at these sites. 

Note: Proportions are calculated based on respondents that answered the question. 

48 51 

56 

81 

0 

10 

20 

30 

40 

50 

60 

70 

80 

90 

Teach Basic Financial 

Education Topics

Funding to Community 

Partners 

Provide Technical 

Expertise 

Free Counseling 

Percentage of Banks 

Figure 1.8: Financial Education and Outreach (Percent) 

Roughly half of all banks used other strategies beyond 

free counseling to promote financial education, including 

teaching basic financial education, providing technical 

expertise, or funding community partners. Almost onethird of all banks (30 percent) participated in all four 

financial education and outreach activities included in the 

survey.
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  • 

Challenges as Obstacles in Offering Financial Products 

and Services to Underserved

Banks were asked about bank business, product-related, 

and regulatory challenges as obstacles to reaching 

unbanked and underbanked consumers. 

About one-third of banks identified fraud as the largest 

perceived major business-related challenge for banks in 

serving the underserved. Behind fraud (32 percent), 

underwriting (28 percent) and profitability (24 percent) 

were also cited relatively frequently as major obstacles. 

Only 16 percent of banks cited nonbank competition as a 

major obstacle. 

Figure 1.10: Bank Business Challenges as Obstacles (Percent)

17 

28 

14 

25 

42 

39 

47 

39 

28 

16 

32 

24 

0 5 10 15 20 25 30 35 40 45 50 

Underwriting 

Nonbank 

Competition 

Fraud 

Major Obstacle Minor Obstacle Not an Obstacle 

Protability

Note: Proportions are calculated based on respondents that answered the question and exludes those that 

reported they did not know enough to assess the degree to which the business challenge was an obstacle.

Thirty percent of banks reported that consumers’ lack 

of understanding of financial products and services was 

a major product-related challenge. Among the other 

product-related challenges, relatively few banks stated that 

lack of familiarity with financial or banking needs of 

underserved consumers (6 percent), developing products 

that meet the needs of the underserved (12 percent), 

effectively marketing products to the underserved (19 

percent), and lack of consumer demand (18 percent) were 

major challenges in offering financial products and 

services to unbanked and underbanked consumers. 

Figure 1.11: Product-Related Challenges as Obstacles (Percent)

Note: Proportions are calculated based on respondents that answered the question and excludes those 

that did not know enough to assess the degree to which the product-related challenge was an obstacle.

26 

19 

40 

10 

30 

55 

37 

42 

43 

45 

19 

18 

6 

31 

12 

0 10 20 30 40 50 60 

Effective Product 

Marketing 

Lack of Customer 

Demand 

Lack of Familiarity with 

Consumer Needs 

Lack of Consumer 

Understanding 

Product Development 

Major Obstacle Minor Obstacle Not an Obstacle 

One in three banks (35 percent) cited regulatory 

requirements as a major obstacle in serving unbanked 

and underbanked consumers and an additional 30 

percent cited them as a minor obstacle. Thirty-four to 40 

percent of these banks reported that BSA/anti-money 

laundering (34 percent), fair lending/compliance risks (35 

percent), and customer ID concerns (40 percent) were 

major obstacles in offering financial products and services 

to underserved consumers. In contrast, a relatively smaller 

proportion of banks (almost 20 percent) stated that thirdparty relationship risk was a major obstacle. 

Figure 1.12: Regulatory Challenges as Obstacles (Percent)

Note: Proportions are calculated based on respondents that answered the question about the regulatory 

environment and excludes those that did not know enough to assess the degree to which regulatory challenges 

were obstacles. 

Major Obstacle Minor Obstacle Not an Obstacle 

16 

21 

16 

11 

23 

41 

43 

49 

48 

30 

20 

35 

34 

40 

35 

0 10 20 30 40 50 60 

 Third-Party Risk 

 Fair Lending/

Compliance Risk 

 BSA/Anti-Money 

Laundering 

 Customer ID 

Regulatory 

Environment 

Note: Proportions are calculated based on respondents that answered the question. 

33 

30 

74 

11 

53 

23 

1 

41 

0 

10 

20 

30 

40 

50 

60 

70 

80 

90 

100 

Public Fairs/

Gatherings Workplaces K-12 Schools Government 

Sites 

Bank 

Branches 

Vocational 

Schools/

Colleges 

Military 

Installations 

Nonprot/

Community 

Organizations 

Percentage of Banks 

Figure 1.9: Financial Education and Outreach 

Locations (Percent) 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  • 

Results by Asset Size

The full report and appended tables provide additional 

findings and also disaggregate results for the largest 25 

banks (with assets in excess of $38 billion), midsize banks 

(with assets in excess of $1 billion but less than $38 

billion), and the smallest banks (with assets of less than 

$1 billion). In some respects, the results do not vary 

significantly among the three groups. However, the report 

does show that each group has some relative strengths to 

draw on in their efforts to meet the needs of underserved 

consumers, including the following examples:

• The largest banks tended to have lower initial deposit 

requirements on basic checking and savings accounts 

and accepted a broader range of foreign identification 

for account opening;

• Small and midsize banks were more likely not to 

charge maintenance fees on basic checking and 

savings accounts, had lower required account balances 

to avoid certain fees, and charged lower fees when 

they applied;

• The largest banks were more likely to engage in a 

greater range of educational and outreach activities;

• The largest banks were more likely to report actively 

marketing products or services customized to the 

needs of the unbanked and underbanked and to offer 

a wider array of auxiliary products and services; 

• Small and midsize banks were more likely to make 

unsecured personal loans in amounts under $2,500, to 

charge less on the auxiliary products and services they 

did offer, and to make funds available on the same 

day when cashing checks.

Opportunities to Expand Access to Mainstream 

Financial Services

Based on the Bank Survey results, we identify five opportunities banks could explore to expand access to 

mainstream financial services: 

1. Expand Offerings of Basic, Low-Cost Checking and 

Savings Deposit Accounts 

The Bank Survey finds that on the most basic checking 

deposit account without direct deposit that 48 percent of 

banks had minimum opening balance requirements of 

$100 or more and 22 percent had monthly maintenance 

fees of more than $3. For basic savings accounts, the 

median opening and average balance requirement to avoid 

a fee was $100. 

To broaden economic inclusion efforts, banks should 

consider offering low-cost electronic, card-based 

transaction deposit accounts that do not allow overdraft 

and NSF fees. The survey found that around one in five 

banks offered electronic, card-based accounts and some 

evidence that those accounts which were strictly cardbased and electronic (no paper check writing feature) had 

lower average opening balance requirements and monthly 

maintenance fees. The design of such accounts also 

reduces the overdraft risk banks face with accounts that 

permit check writing and may make it possible to eliminate NSF and overdraft fees, further reducing costs for 

consumers. These accounts may be even more attractive 

to consumers when paired with basic savings accounts 

with low minimum balance requirements. 

2. Offer Additional Transaction Services to Underserved Households, Including Noncustomers

Consumers’ use of nonbank financial services providers to 

meet their needs points to market opportunities for depository institutions. Some consumers, for example, use 

money orders in lieu of cash or checks to pay monthly 

rent or utility bills. Yet, one in three banks did not offer 

money orders to accountholders and two-thirds did not 

offer this product to noncustomers. In addition, unbanked 

consumers frequently need a way to cash checks. And 

consumers, especially those with family outside the US, 

often use nonbank financial services providers to make 

domestic or international remittances. The survey found 

that 71 percent of banks cashed payroll checks for basic 

accountholders and 47 percent offered this service to 

noncustomers. Moreover, one-half and two-thirds of banks 

offered international and domestic remittance products, 

respectively, to accountholders, but only nine and eleven 

percent of banks offered international and domestic remittance products, respectively, to noncustomers. Banks 

seeking to expand financial services to underserved 

consumers could consider offering a broader range of 

auxiliary transaction services to accountholders and 

noncustomers. 

3. Enhance Small-Dollar Loan Product Marketing

Most banks (82 percent) offered unsecured personal loans 

with a minimum loan amount of $2,500 or less, with many 

setting no minimum loan amount. However, 20 percent of 

households that obtained credit from payday lenders and 

almost 18 percent from pawn shops did so primarily 

because they thought that banks did not offer small-dollar 

loans.2 While some proportion of borrowers that obtain 

small dollar credit from nonbank providers may not qualify for bank loans (about one-third of banks reported that 

underwriting was a major obstacle in offering financial 

products to unbanked and underbanked consumers), the 

gap between the small-dollar loan availability reported by 

2 See the 2011 FDIC National Survey of Unbanked and Underbanked 

Households Report at http://www.economicinclusion.gov.
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  • 

banks and perceived by consumers suggests that banks 

could improve marketing of these products.

4. Utilize Partnerships with Community Organizations 

to Promote Checking and Savings Account Ownership 

Community outreach through collaborations with community groups was identified as the most effective strategy for 

developing relationships with these populations. Despite 

this recognition, only about half of all banks reported 

using partnerships with organizations to promote opening 

checking or savings accounts. These findings suggest that 

banks may benefit from expanding collaborative efforts to 

promote access to mainstream deposit accounts. 

5. Consider Expanding Retail Strategies to Build Relationships with Unbanked and Underbanked Consumers

The most frequently chosen retail strategies to make 

branches more convenient or welcoming to consumers 

were automated telephone banking, multilingual staff, and 

off-premise ATM locations. Banks engaged in these strategies generally reported that they were very effective or 

effective tools for developing a relationship with 

unbanked and underbanked consumers. Banks that have 

not deployed certain retail strategies (e.g., 63 percent of 

banks do not offer extended hours or services on weekends) should consider whether adding such options could 

better position the institution to build relationships with 

underserved consumers.