FDIC Advisory Committee on Economic Inclusion

Safe Accounts

How Key Is Delivering Today

Dave Bowen

SVP

Consumer Client Segmentation Strategy and

Product Management

May 2013
2

Agenda

• Key’s Approach to Product Development and Management

• Meeting the Needs of the Underbanked/Underserved

• Recent Product Developments

– KeyBank Access Account

– Key Basic Line of Credit

– Posting Order

– Disclosure

– Good Funds

• Client Choice, Client Control
3

Product Development – Guided By the ‘Fairness Pyramid’

• Client Choice

– Ability to opt-in or opt-out of 

products/services to avoid fees

• Market-Based/ Competitive

– Fees within a range of market prices 

by category

– No high side outliers

– Industry standard practices and 

treatments

• Formulaic

– Applies a “blind” standard for 

assessing fees and/or refunding fees

• Disclosure

– Clear, understandable disclosure of 

processes, policies, fees and fee 

avoidance

• Compliance

– Compliance is mandatory In Compliance/Legal

Fully Disclosed

Formulaic

Market-Based/

Competitive

Client

Choice/

Design

Fairness
4

Think Differently

• Safety – Do No Harm

– The Financial Hippocratic Oath

– Features fee structures and underwriting practices should not reduce a 

consumer’s financial well-being. Communications about fees, terms and 

conditions should be presented clearly and intelligibly.

• Inclusion - Accessibility and Convenience

– Promote genuine accessibility and convenience for consumers in every possible 

dimension – geographically, temporally, linguistically, and culturally

• Financial Capability – Design for Consumer Success

– Empower customers to make wise money choices. 

– Communication should be relevant to specific concerns and financial situations, 

coincide in a timely fashion with key life events/ decision and be immediately 

actionable 

• Pathways – Create Upward Mobility

– Help consumers grow and evolve in their financial lives by expanding their 

choices and offering products that meet needs at multiple phases of the 

consumer lifecycle. 

– Design a pathway from the financial present to a prosperous future, helping 

consumers move from the product that is right today to the product that will be 

right tomorrow.
5

Think Differently

• The Underserved Lens

– Underserved along a client continuum

– View all segment strategies, tactics and initiatives through an 

underserved “lens”

– Diminish the prominence to increase leverage

– Don’t just “check the box”

• Client Experience

– Ensure that the client experience is what we want it to be

– Standard Operating Procedure Unique to Underserved

• How We Do Business

– Policies, procedures, systems and business rules that make serving the 

underserved difficult

– Details matter
6

KeyBank Access Account

• Introduced in 2011

• “Checkless” checking account

– Debit Card access

– Online banking and bill pay

– Text and email alerts

– No fee Direct Deposit or ATM Deposit

• No overdraft or NSF fees 

– Account does not permit overdrafts

– No checks so no NSF fees

• $5.00 per month waived if 2 or more transactions or $200 or more in 

deposits

• Sold through branch and Key@Work bank-at-work channels

– 7-8% of total consumer checking sales ~11,000 per year

– Year over year sales increase of 9%
7

Other Client-Centric Changes

• Key Basic Line of Credit

– Small line amounts $250 to $1,500

– Sub-Prime product

• $25.00 annual fee

• Prime + 15.99%

– Clients are underwritten for the “best” line of credit for which they qualify

– Product characteristics:

• Units: 3,235

• Commitment: $3,540,050

• Average Commitment: $1,094

• Balance: $1,899,907

• Average Balance: $587

• 1.5X active, 2X utilization, 3X delinquency, chargeoff 3.5X

• Posting Order Changes

– Chronological - reflect order in which client initiated transactions

• PEW Disclosure

• Engineering float out of the system; increase good funds
Pew Disclosures

8

$ 50.00

$ 5.00

$ 500.00

 7.00

 -

$ -

$ 2.50

$ 33.00 per item

$ 39.00 per item

$ 15.00

$ 34.00

$ 25.00

Overdraft Penalty Fee

1-2 in a twelve month period $ 33.00

>2 in a twelve month period $ 39.00

Maximum Number of 

Overdraft Penalty Fees per Day 5.00

Extended Overdraft Penalty Fee $ 28.50

Overdraft Transfer Fee

$ 10.00

$ 5.00

$ 10.00

Posting Order

Deposit Hold Policy . Cash deposit with teller: next business day

When funds deposited to . Cash deposit at KeyBank ATM: next business day

your account are available . Check deposit with teller: next business day

. Check deposit at KeyBank ATM: 2nd business day

. Cash or check deposit at a non-KeyBank ATM: 5th business day

. Direct deposit: same business day

. Wire transfer: next business day

. If something causes a longer hold on a deposit, the first $200 of that deposit

will be made available the next business day.

Dispute 

Resolution Dispute Resolution Agreement

KeyBank National Association BASIC TERMS AND CONDITIONS

Key Express Checking Account

Greater Cleveland

Effective: October 15, 2012

Today's date: March 4, 2013

Account Opening 

and Usage

Minimum Deposit Needed to Open Account

Monthly Fee

Requirements to Waive Monthly Fee

or more credited to your account as deposits (including transfers into 

this Account) during a statement cycle.

customer initiated transactions (ANY deposits, withdrawals, which 

includes transfers) on your account during a statement cycle

Interest Rate Interest not paid on this account.

ATM Fees for using your bank’s ATM

ATM Fees for using another bank’s ATM

Non-Sufficient Funds (NSF) Fee

Returned Check Fee per declined check written to your account

Stop Payment Fee per item to stop payment for up to 6 months or for a range of items

Account Closing Fee if account closed within 180 days of opening

Other Service Fees please consult the back of this document for a list of additional service 

Overdraft Options 

for Consumers with 

Debit Cards

Option A: 

Default

per overdraft covered by bank advance

per overdraft covered by bank advance

every 5th day the account is overdrawn, starting 5 days after the 

account is first overdrawn

Option B:

Any claim shall be resolved, upon the election of you or us, by binding arbitration. 

There shall be no authority for any claims to be arbitrated on a class action or private 

attorney general basis. Furthermore, arbitration can only decide your or our claim(s) 

and may not consolidate or join the claims of other persons that may have similar 

claims.

per overdraft covered by transfer from linked savings account

per overdraft covered by transfer from linked Preferred Credit Line

per overdraft covered by transfer from linked Cash Reserve Credit

Processing Policies

Currently we process items from highest dollar amount to the lowest dollar amount 

within certain categories. Prior day transactions post before current day transactions 

in the following order: pending credits, pending debits, credits, ATM/everyday debit 

card, all other debits.

The order in which withdrawals 

and deposits are processed

Helpful ways to avoid fees:

Service Charges in Connection with an Account:

• Banking Card Charges:

There are charges for certain types of Banking Card transactions. Please refer to the Bank’s Disclosure Statement and Terms and 

Conditions for Electronic Fund Transfer Transactions for the description and amount of each type of charge. 

• Overdraft Item and Return Item Charges: 

Overdraft Item Charges and Return Item (NSF) Charges will be assessed to your Account according to the tiered transaction limits 

described below: 

We will count each overdraft and returned item over a rolling 12 statement period (current statement period and previous 11 statement 

periods) to determine the charge to be assessed. 

Tier #OD/NSF Transactions OD/NSF Per Item Charge

1 1-2 $33.00 

2 3 and above $39.00 

• Recurring Overdraft Service Charge:

In addition to a base overdraft service charge (and excess overdraft charge, if any) assessed for each item that overdraws your 

Account, if your Account remains overdrawn for five consecutive business days your Account will be assessed a Recurring Overdraft 

Service Charge of $28.50 . 

• Daily Overdraft Item (OD) and Return Item (NSF) Charge Cap:

There is a daily cap of 5 OD and NSF charges per account. Examples: if 10 items (e.g. check or ATM withdrawal) are paid against 

insufficient funds overdrawing your account during one day, you will only be charged OD charges for 5 items that day. If 4 items are 

paid against insufficient funds overdrawing your account and 4 items are returned, you will only be charged for 5 items. If you have a 

line of credit such as Cash Reserve Line of Credit, Preferred Credit Line, KeyBasic Credit Line or Key Equity Options linked to your 

Account for overdraft protection and your line of credit does not have sufficient funds to cover items presented for payment and OD or 

NSF charges are assessed, the daily cap on OD and NSF charges will apply. 

• Monthly Overdraft Item (OD) Charge Cap:

There is a monthly cap of 20 OD charges per account per service charge cycle. Once the monthly cap of 20 OD item charges has been 

reached during the service charge cycle, items will not be paid if there are insufficient funds in your account for the remainder of the 

service charge cycle. They will be returned and you may be charged a Return Item (NSF) charge. If you have a line of credit such as 

Cash Reserve Line of Credit, Preferred Credit Line, KeyBasic Credit Line or Key Equity Options linked to your Account for overdraft 

protection, the monthly cap on OD charges will not apply. 

• Stop Payment Charge (for each stop payment or to renew a stop payment on a 

check/withdrawal) $34.00 

• To stop payment or to renew a stop payment on a range of checks (multiple items 

in sequence) $34.00 

• Chargeback Fee (for each check deposited to your account that is returned to us 

unpaid) $15.00 

• Charge for Account Early Close-out (Account closed within 180 days after opening, 

excluding IRA, Keogh, Certificates of Deposit and Club Accounts) $25.00 

• Charge for Handling Legal Process (for processing legal papers if you or your account 

are affected by any litigation) $100.00 

• Charge for Copy of Item(s) 

 If your checks and digital images of checks are held by KeyBank: 

 Up to 12 copies of canceled checks and/or digital images of canceled checks per 

calendar year: No Charge

 Charge for Each Copy in excess of 12 per calendar year: $3.00 

 If you receive an Imaged Items Statement 

 Charge for Each Copy of a Check or Digital Image of a Check: $3.00 

• Charge for Each Copy of Statement $6.00 

• Duplicate Statement Service Charge:

If you request duplicate copies of your deposit account statement be sent on a monthly basis, your Account will be charged $10.00 per 

month for this service. If you have combined statements for your deposit accounts only your primary Account will be assessed the 

monthly charge. 

• Fedwire Service Charge

Incoming (domestic and International)

Domestic Outgoing

International Outgoing 

$20.00 

$30.00 

$45.00 

• Incoming Wire Transfer Notification Fee:

If you have requested that you be notified by phone of incoming wire transfers, each incoming wire transfer charge will be increased by 

$5.00 . 

• Returned Statement Charge

If your statement is returned to the bank due to an incorrect address, your Account will be assessed a $10.00 Returned Statement 

Charge. For each month that follows (months two through a maximum of 12 consecutive months) where a current address has not

been provided, a Statement Information Safekeeping Fee of $10.00 per month will be assessed. 

• Safe Deposit Box Rental Charge Varies based on size of box 

• Statement Special Handling Charge:

If you request special handling of your deposit account statement, your Account will be charged $10.00 per month for this service. If you 

have combined statements for your deposit Accounts only your primary Account will be assessed the monthly charge. 

UNCLAIMED FUNDS

After a period of five (5) years of no account activity or contact with you, we are required to forward funds on deposit to the Ohio Department of 

Commerce, Unclaimed Funds Division. You may file a claim with the State of Ohio (Department of Commerce) for your unclaimed funds. We are not 

liable for any funds we transfer to the Unclaimed Funds Division. 

Personal Checking Account Fees and Disclosures

Greater Cleveland 

Effective October 15, 2012

KeyBank National Association

Member FDIC

Today’s Date Is March 4, 2013

Key Express Checking Account

This Personal Checking Account Fees and Disclosures (“Disclosure”) provides information about deposit accounts we offer. While this Disclosure is 

accurate as of the effective date noted above, specific product features may be changed from time to time. A copy of the current Disclosure may be 

obtained upon request by contacting us. Current Interest Rate information may be obtained by contacting your KeyCenter or by calling 1-800-

KEY2YOU® (1-800-539-2968) TDD 1-800-KEYTDD1(1-800-539-8331).

Key Express Checking Account

The minimum deposit required to open a Key Express Checking Account is $50.00 . This Account pays no interest. If you receive an image statement (a 

monthly statement that contains images of the front of your cancelled checks), your Account will be charged a $3.00 Imaged Item(s) with Statement 

Charge per monthly statement cycle. If you opt to receive your Account statement on paper instead of electronically, your Account will be charged a 

$3.00 Paper Statement Charge per monthly statement cycle. There is no Paper Statement Charge if you receive your Account statement electronically 

through Key's Online Banking service. If you receive a combined Account paper statement and your combined statements includes statements for other 

types of checking and savings Accounts (excluding Key Advantage Money Market Checking Account, Key Privilege Checking Account, Key Privilege 

Select Checking Account, Key Private Bank Personal Checking Account, Key Private Bank Money Market Checking Account, Sweep Checking 

Accounts, Nursing Home Direct Deposit or Key Pre-Need Funeral Trust) your checking account may be assessed the $3.00 Paper Statement Charge. 

There is no monthly Maintenance Service Charge if one of the following requirements is met:

• You have deposits (including transfers into this Account) totaling $500.00 or more credited to your Key Express Checking Account 

during a statement cycle. 

• You have at least 7 customer initiated transactions (ANY deposits, withdrawals, which includes transfers) on your Key Express 

Checking Account during a statement cycle. 

If neither of these requirements is met, the Key Express Checking Account monthly Maintenance Service Charge will be $5.00 . 

Additional Account Information

In addition to your specific Account service charges described above, your Account may also incur service charges as described in the OTHER 

CHARGES section listed at the end of this document. Your Account is also subject to our Deposit Account Agreement and Funds Availability Policy.

The term Withdrawal means any check, any preauthorized transfer or withdrawal (including any electronic debit or automatic payment), and any 

telephone transfer or wire transfer of funds from your Account. The term checks/withdrawals paid as referenced in this Disclosure means a check, or 

each withdrawal made in any channel. Deposit means a deposit of funds into your Account, including any electronic direct deposit, automatic deposit or 

telephone transfer.

The Daily Balance is the balance in your Account each day. The Average Daily Balance is calculated by adding the Daily Balance in your Account for 

each day of the statement period and dividing that amount by the number of days in the statement period.

We provide detailed statements for all Accounts. Your canceled checks and digital images of your canceled checks will be held by KeyBank in our 

secure system. Imaged items statements (digital images of the front of your canceled checks included with your Account statement) are available upon 

request. If you request a copy of a canceled check, a digital image of a canceled check or an item, we will send you the copy (refer to the OTHER 

CHARGES section for applicable service charges), provided that the check or item was presented for payment within the time period during which we 

maintain copies of checks (normally seven years). 

OTHER CHARGES

Inactive Account Fee and Interest Reduction

Unless prohibited by applicable law, Checking and Savings (excluding Key4Kids Savings Accounts) Accounts with balances of less than $5000.00 will 

be charged a $5.00 monthly Inactive Account Fee (“Fee”) after 3 months of inactivity on a Checking Account and after 12 months of inactivity on a 

Savings Account. This Fee will be assessed in addition to normal Account service charges. An Account is classified as inactive if there have been no 

customer initiated transactions (ANY deposits, withdrawals, which includes transfers) during the past 3 months for Checking Accounts and 12 months for 

Savings Accounts. The Inactive Account Fee and interest reduction are governed by Federal law. If you have an inactive interest bearing Account, the 

interest rate will be changed to .01 %. 

An Inactive Account notice will be sent to you prior to your Account being classified as inactive. In order to avoid the Fee and the interest reduction, you 

must either make a deposit to or a withdrawal from this Account or have a transfer to or from this Account. You may also avoid the Fee and interest 

reduction if you sign and return the notice you will receive prior to your Account being presumed abandoned.

Excess Telephone Inquiry Service Charge

(This charge applies to all types of Checking Accounts.)

If the number of automated (a call during which you do not speak to an employee) telephone calls for general account information exceeds 8 per 

statement period, your Checking Account will be charged $0.75 per call. If the number of employee assisted (a call made directly to an employee or 

transferred from an automated telephone inquiry) telephone calls for general account information exceeds 3 per statement period, your Checking 

Account will be charged $1.50 per call. If you request general account information on more than one account during the same telephone call each 

account is treated as a separate telephone call and may be assessed a charge as described above. General account information includes account 

balance, checks that have been paid, electronic transactions that have been paid, deposits that have been made and interest information. If your request 

for general account information results in a request for service, such as a copy of an item or a stop payment, no charge for the employee assisted 

request for general account information will apply and the call will not be counted towards the limits described above. However, any applicable charges 

for the services requested will apply.

Service Charges in Connection with an Account:
KeyCorp Highly Confidential

9

More Client Choice and Control

Key attempts to pre-approve and offer overdraft protection at account opening across the 

spectrum of creditworthiness:

Preferred Credit Line

Cash Reserve Credit

Key Basic Line of Credit

Choice to establish Savings Overdraft Protection service 

Choice to opt-out of SmarterPay service – all overdrafts

Choice to opt-out of ATM/debit card overdrafts – Reg E 

Key Coverage Checking with differentiated overdraft pricing

Key Access Account with No Overdraft Capability

New Reloadable Debit – no checks

Lower cost check cashing

No charge alerts to warn of balance issues

No charge mobile and online banking – permits balance transfer anytime, anywhere

Key offers clients a variety of options to manage cash flow and choose the client 

experience they prefer to manage unexpected overdrafts

CHOICE

CONTROL