506

Minutes

of 

The Meeting of the FDIC Advisory Committee on Economic Inclusion 

of the 

Federal Deposit Insurance Corporation 

Held in the Board Room 

Federal Deposit Insurance Corporation Building 

Washington, D.C. 

Open to Public Observation 

October 18, 2017 – 9:07 A.M. 

The meeting of the FDIC Advisory Committee on Economic Inclusion (“ComE-IN” or 

“Committee”) was called to order by Martin J. Gruenberg, Chairman of the Board of Directors of 

the Federal Deposit Insurance Corporation (“Corporation” or “FDIC”).

 The members of ComE-IN present at the meeting were Robert A. Annibale, Global 

Director, Citi Microfinance and Community Development; Michael S. Barr, Professor of Law, 

University of Michigan Law School; Janie Barrera, Founding President and CEO of LiftFund, 

Inc.; Ted Beck, President and Chief Executive Officer (“CEO”), National Endowment for 

Financial Education; Kelvin Boston, Executive Producer and Host of PBS’ Moneywise with 

Kelvin Boston; José Cisneros, Treasurer, City and County of San Francisco, California; Martin 

Eakes, CEO, Self-Help/Center for Responsible Lending; Wade Henderson, President and CEO, 

Leadership Conference on Civil Rights, and Counselor to the Leadership Conference on Civil 

Rights Education Fund; Andrea Levere, President, Prosperity Now; Patricia A. McCoy, Liberty 

Mutual Professor of Law, Boston College Law School; Alden J. McDonald, Jr., President and 

CEO, Liberty Bank and Trust Company; Bruce D. Murphy, Executive Vice President and 

President, Community Development Banking, KeyBank National Association; Phillip L. Swagel, 

Professor in International Economic Policy, University of Maryland; and John C. Weicher, 

Director, Center for Housing and Financial Markets, Hudson Institute. 

Nandita Bakhshi, President and CEO, Bank of the West; Ester R. Fuchs, Professor, 

School of International and Public Affairs, Columbia University; Mark W. Olson, Chairman, 
507

October 18, 2017 

Treliant Risk Advisors; Manuel Orozco, Senior Associate at the Inter-American Dialogue and 

Senior Researcher, Institute for the Study of International Migration, Georgetown University; and 

John W. Ryan, Executive Vice President, Conference of State Bank Supervisors, were absent 

from the meeting. 

 The sole member of the Corporation’s Board of Directors present at the meeting was 

Martin J. Gruenberg, Chairman. Jonathan Miller, Designated Federal Officer for the Committee 

and Deputy Director, Division of Depositor and Consumer Protection, also was present at the 

meeting. 

 Corporation staff who attended the meeting included Michelle Adams, Lee Ann Antol, 

Valerie J. Best, Rebecca Bittle, Michael W. Briggs, Karyen Chu, Christine M. Davis, Stephanie 

M. Downing, Keith S. Ernst, Lessie P. Evans, Richard Foley, Janet R. Gordon, Shamara L. 

Humbles, Nicholas S. Kazmerski, Laura Lawrence, Joan M. Lok, Christopher Lucas, Jonathan 

Miller, Janet V. Norcom, Joyce M. Northwood, Gerard S. Parnacott, Mark Pearce, Lavonne R. 

Pherson, Kristopher Rengert, Floyd Robinson, Casey Snyder, Patience R. Singleton, Kimberly 

Stock, Thomas E. Stokes, and Lori Thompson. 

Chairman Gruenberg opened and presided at the meeting. He began by observing that 

today’s program captured in many ways the work the Committee has done over the past several 

years. He stated that the focus of the morning session was on the FDIC’s continuing effort to 

expand access to the mainstream financial system for everyone who lives in the United States. 

Chairman Gruenberg reminded Committee members that much of the focus in previous 

Committee presentations had been on large institutions that offered accounts known as Safe 

Accounts, and that the FDIC also wanted to include in its outreach efforts for the smaller 

institutions to offer Safe Accounts, as well. He observed that, in many ways, community banks 

and smaller banks are vehicles for access to the financial system. 

Next, Chairman Gruenberg provided an overview of the meeting agenda, identifying the 

following four major topics: Safe Accounts offered by smaller institutions, FDIC bank survey 

results, financial inclusion for persons with disabilities, and research updates on neighborhood 

access to bank branches. Regarding the presentation on research updates regarding neighborhood 

access to bank branches, Chairman Gruenberg advised that the research was focused particularly 

on populations in the United States that continue to rely on access to bank branches for their 

banking services. He observed that much of the focus in today’s discussion will be on 

technology and online access, but noted that large numbers of people, particularly lower income 

and elderly populations, continue to rely heavily on bank branches for access to financial 

services, and that fact was something the FDIC wanted to understand better. Chairman 

Gruenberg then turned the discussion over to Jonathan Miller, Deputy Director, Division of 

Depositor and Consumer Protection (“DCP”), moderator of the first panel, “Safe Accounts 

Update.”
508

October 18, 2017 

Mr. Miller advised that the panel would update the Committee on work being done by the 

FDIC to expand economic inclusion and the reach of Safe Accounts, including those accounts 

that meet the Cities for Financial Empowerment’s National Account Standards. He then 

introduced Melissa “Missy” Burba, Senior Vice President for First Commonwealth Bank; 

Victoria Goins, Program Manager for Bank On Greater Pittsburgh; and Ben Joergens, Director of 

Financial Empowerment for Old National Bancorp. 

Ms. Burba began by noting that every community bank she speaks with acknowledges the 

importance of educating customers on financial health and how to improve customers’ financial 

lives. She explained that First Commonwealth Bank’s financial education program coordinator 

provides financial education for adults, children, and bank employees. She said that the bank’s 

community lending manager is also an advocate for unbanked and underbanked populations, and 

partners with Bank On Greater Pittsburgh in those efforts. Ms. Burba then provided an overview 

of the bank’s personal checking account options, including Hometown Checking, SmartPay 

Card, and health savings accounts. Ms. Burba recalled that the SmartPay Card was initially 

marketed by the bank as a banking solution for teens and college students, and it is now being 

considered by the bank as a product for unbanked and underbanked populations. Ms. Burba 

reported that First Commonwealth Bank’s SmartPay Card met criteria for Bank On certification 

in May 2017, and was the ninth bank in the nation to get Bank On certification for that product. 

Ms. Burba said the bank is in the process of positioning the SmartPay Card with its sales team as 

a good option for unbanked and underbanked populations. Ms. Burba observed that, even though 

the bank has been marketing credit cards for only a year, the consumer credit card and secure 

credit card were more successful than the bank had anticipated, with 11 percent of account 

openings in the past year coming from credit card products. 

Concluding her presentation, Ms. Burba briefly addressed the Fund My Future Program 

that originated in Western Pennsylvania to support students of Allegheny County’s network of 11 

Propel public charter schools, providing incentives to underserved parents to start saving for their 

children’s college. Ms. Burba reported that children are three times more likely to go to college, 

and four times more likely to graduate from college, if they have a savings account. Ms. Burba 

stated that the program expanded September 1, 2017, to all of Allegheny County, and the goal is 

to expand it to all of Western Pennsylvania. 

Ms. Goins then briefed the Committee on Bank On Greater Pittsburgh’s focus on serving 

the unbanked and underbanked, and pointed out that Bank On Greater Pittsburgh is a program 

supported by the Urban League of Greater Pittsburgh. Ms. Goins discussed the program and the 

needs assessments that were conducted in order to determine what was needed for Bank On 

Greater Pittsburgh to be effective in Allegheny County. Reiterating the fact that the mission of 

Bank On Greater Pittsburgh was to begin to address the needs of the unbanked and underbanked 

by providing them an affordable, sustainable account platform that was not predatory, Ms. Goins 

pointed out that meant providing financial education to program clients that were accustomed to 

the immediate gratification provided by payday loans and quick cash outlets. Ms. Goins also 
509

October 18, 2017 

noted that financial literacy partners included First Commonwealth and the Community College 

of Allegheny County. Next, Ms. Goins expressed concern over the difficulty individuals in this 

market experience sustaining livelihoods through emergency situations. Ms. Goins noted that 

Bank On Greater Pittsburgh received a Bank On capacity grant from the Cities for Financial 

Empowerment. She explained that the grant is being used to provide financial education, provide 

technical platforms that will possibly eliminate the aversion some individuals have to entering 

bank branches, and technically advance the Bank On website in order to attract millennials. In 

closing, Ms. Goins announced that Bank On Greater Pittsburgh is partnering with the Cities for 

Financial Empowerment, the FDIC, the Office of the Comptroller of the Currency, and 

Neighborhood Allies to host an event that will be held in Pittsburgh on October 30, 2017, and 

will showcase the National Account Standards. Ms. Goins added that event information is 

available at: www.joinbankon.org.

Mr. Joergens then briefed the Committee on the EZ Access Account offered to 

underserved markets by Old National Bancorp and pointed out that Old National Bancorp 

implemented the first Bank On program in the Midwest. He explained that when the program 

was first developed, Old National Bancorp conducted community needs assessments, and 

surveyed nonprofit organizations, recovery centers, and correctional facilities to determine the 

most beneficial product to offer. Mr. Joergens then listed the features of the EZ Access Account 

that was developed for this market. He pointed out that the bank’s President and CEO, Bob 

Jones, was a member of the Bank On National Advisory Board, and committed the program to 

providing financial education to underserved populations. To that end, the bank partnered with 

the National Financial Educators Council to develop the Old National Real Life Finance 

curriculum, with 68 employees trained to teach the program’s wide variety of financial education 

workshops that include financial psychology, account management, credit, budgeting, insurance, 

retirement, and investments. Turning to the importance of helping the next generation, Mr. 

Joergens detailed the curriculum expansion that was implemented to reach anyone from pre-K to 

adult. Mr. Joergens concluded by providing information on a twelve-week financial success 

program Old National Bancorp developed to empower at-risk adults who had been incarcerated 

for non-violent offenses. 

In the discussion that followed, Committee members offered a number of comments and 

suggestions. Member Annibale began by noting that underserved segments are composed of 

large numbers that have not been intentionally targeted by most large financial institutions and 

congratulated the speakers on their work with those underserved segments. Member Levere 

observed how data actually changes policy and behavior. She noted that the liquid asset poverty 

number of $400 that had been cited from the Federal Reserve Board was used to bring in people 

from Pittsburgh who had not previously considered themselves as being in one of those targeted 

populations. Ms. Goins, in response to Member Levere’s inquiry about the history of racial 

discrimination and racism in Pittsburgh, then reflected on how racial discrimination and 

disparities impact the work being done, and discussed the focus on homeownership. Discussion 

followed regarding Member Swagel’s concerns regarding the availability of for fee or no fee 
510

October 18, 2017 

overdrafts in products designed for underserved segments of the population and the impact of the 

payment system on such availability. Member Henderson suggested that existing disparities are 

created by structural inequality. He expressed his concern that student loans are nondischargeable in bankruptcy, resulting in financial burden for the rest of that individual’s life. 

Discussion followed regarding financial education that addresses student loan debt. Member 

Henderson observed that financial institutions are precluded by the FDIC from hiring individuals 

who may have been previously incarcerated for even minor offenses, and proposed the question 

of whether the FDIC should consider fair hiring policies as a question that should be on the table. 

Member Cisneros commented on the importance of guiding customers to safe places to 

have their accounts, particularly in the aftermath of the Wells Fargo account scandal. Discussion 

followed to address Member Cisneros’ additional concerns regarding negative balances and 

waivable monthly fees. In response to a question posed by Member McCoy, the panel then 

described factors impeding utilization of these products by underserved populations, and efforts 

made to address those challenges. Member Eakes then asked about advice the panel had 

regarding expanding the certification process to other products. In response, the panel identified 

the need for collaboration of all banks to use the same national certification standards, the 

importance of customer financial education, and challenges presented during the certification 

process. Member Murphy pointed out that the Bank On product could be a mass market product 

and its application could extend beyond the underserved market. The panel then addressed 

Member Murphy’s concern regarding branding the product as Bank On, and explained education 

efforts made to minimize any branding confusion. 

Mr. Miller then announced that the meeting would briefly recess. Accordingly, at 10:33 

a.m., the meeting stood in recess. 

*****

 The meeting reconvened at 10:50 a.m. that same day, with Mr. Miller providing context 

for the Committee’s next presentation. Mr. Miller noted that this was the first time the 

Committee had heard from some smaller institutions offering Safe Accounts and acknowledged 

that previous presentations had been by the very large banks. He reminded the Committee of the 

progress seen in the area of Safe Accounts, noting that 87 percent of Americans live in a county 

with a full service branch of one of the institutions offering a Safe Account. Mr. Miller 

acknowledged that there had been no recent survey data to explore the question of Safe 

Accounts, other than the dated FDIC 2011 survey of banks’ efforts to serve unbanked and 

underbanked populations. To fill that knowledge gap, Mr. Miller indicated that the next panel 

would provide results from a survey of banks done in partnership with the FDIC’s Division of 

Insurance and Research and the U.S. Census Bureau. Mr. Miller expressed the hope that the 

survey would provide a basis for the Committee to reflect on what more can be done to help 

smaller institutions consider whether Safe Accounts could work for them, as they have proven to 

work so effectively for larger institutions. Mr. Miller then introduced Karyen Chu, Chief, 
511

October 18, 2017 

Consumer Research and Examination Support Branch, DCP, to moderate the next panel, “2016 

FDIC Bank Survey Results.”

 Ms. Chu introduced the members of panel, including Kristopher Rengert, Senior 

Consumer Researcher, DCP, and Joyce Northwood, Senior Financial Economist, DCP. Ms. Chu 

noted that the FDIC’s economic inclusion research on consumers and households, in particular 

the biannual national survey on unbanked and underbanked households, is well known and 

widely used. She added that the FDIC has a parallel interest in conducting research that provides 

information about economic inclusion efforts and opportunities at banks, and listed 2009 and 

2011 surveys, as well as 2015 qualitative research. Ms. Chu noted that the major purpose of the 

bank survey and research presented today was to explore the availability of accessible and 

sustainable basic entry-level accounts in the U.S. and the accessibility of identification and 

screening policies for account opening. Ms. Northwood’s presentation included an overview of 

the 2016 survey. She also discussed access, or the consumers’ ability to actually open basic 

checking accounts, which is the first component of the framework of assessing economic 

inclusion as it relates to the characteristics of basic checking accounts. Mr. Rengert discussed 

sustainability, the other key component of assessing accounts through this framework. 

Following the panelists’ presentations, Member McCoy opened a discussion on the low 

incidence of Safe Accounts, strong regional differences, and testable hypotheses regarding both 

of those issues. Member Cisneros identified the challenge that has existed for years as how to 

steer people towards safer accounts. He also expressed an interest in obtaining a detailed 

geographic inventory. Member Beck observed that Safe Accounts are in everybody’s best 

interest, including the best interest of shareholders, and suggested that fact would result in a lot 

bigger institution pickup than presenting only the social aspect of the accounts. Member 

McDonald stated it would be helpful to have baseline data to be able to track over time. Member 

Boston initiated a discussion of primary reasons for being unbanked and suggested working with 

the American Bankers Association and state bankers’ associations to make bankers aware of the 

good business sense to offer this product. Member Annibale mentioned the challenge around 

acceptable IDs for both small and large institutions. Member Eakes observed that some of the 

data presented was difficult to interpret and appeared to indicate that very few people get the 

benefit of a Safe Account. He suggested publishing rankings of banks by name, indicating, for 

example, which banks offer no overdraft or NSF fees. The panel responded to Member 

Henderson’s question regarding data collection regarding payday lending when accessible 

accounts are available to the unbanked, as well as his concern regarding the disparity among 

African-American and Latino households. Member Henderson also expressed a desire to use the 

data to promote policies that achieve the Committee’s objectives, and offered to meet with the 

panel in advance of the next survey to discuss the type of data to be collected. Mr. Miller pointed 

out that the survey instruments were shared with the Committee, and are published in the Federal 

Register with a request for public comment. Mr. Miller stated that the panel would continue to 

share the instrument with the Committee and will arrange calls to receive Committee members’ 
512

October 18, 2017 

reactions and comments. Member Barr agreed with Member Eakes that overdraft fees, both 

amount and incidence, are issues. 

 Mr. Miller announced that meeting would recess for lunch. Accordingly, at 11:57 a.m., 

the meeting stood in recess. 

*****

 The meeting reconvened at 1:26 p.m. that same day, at which time Thomas Stokes III, 

Atlanta Regional Manager for Community Affairs, DCP, and moderator of the panel on 

“Financial Inclusion for Persons with Disabilities,” emphasized the commitment to improving 

economic inclusion of people with disabilities. Mr. Stokes discussed the three-part focus on 

collaboration with partners, to include the Consumer Financial Protection Bureau (“CFPB”) and 

the National Disability Institute; enhancement of the suite of educational resources; and pursuit 

of initiatives to identify and disseminate information about inclusive products and practices. Mr. 

Stokes then introduced Thomas Foley, Deputy Director for the World Institute on Disability; 

Anthony Poluch, Senior Vice President and CRA Officer for Bryn Mawr Trust Company; and 

Joseph Keefer, Executive Vice President for Bryn Mawr Trust Company. 

 Mr. Foley opened the presentation by noting that nearly 75 percent of the staff of the 

World Institute on Disability has disabilities. He discussed his own journey with financial 

education and the importance of taking a financial empowerment class that changed his life. Mr. 

Foley discussed financial education tools provided by the World Institute on Disability that target 

people who have disabilities, to include the Equity magazine and the Equity book. Mr. Foley 

shared with the Committee that nearly 50 percent of individuals with disabilities are unbanked, 

but observed that much progress has been made in the last ten years. Mr. Foley then discussed 

some of the factors that contributed to that change, to include intentionality, policy changes, and 

business decisions regarding inclusion. He mentioned the CFPB’s Focus on People with 

Disabilities Guide, which is the companion guide to the CFPB’s Your Money, Your Goals

financial toolkit, and pointed out that the guide specifically focused on the unique issues often 

faced by people who have disabilities. Mr. Foley informed the Committee that the FDIC helped 

recruit 34 disability organizations to be part of this first cohort as this resource is rolled out and 

acknowledged the roll-out has been a great success because the disability organizations were 

responding very positively to this financial inclusion and technical assistance. Mr. Foley 

provided the Committee with information on upcoming training and webinars. He discussed the 

Achieving Better Life Experience (“ABLE”) Act that allows people who have disabilities to save 

money without losing disability benefits, thereby contributing to the rebirth of hope for an entire 

group of people around both employment and economic development. Mr. Foley concluded his 

presentation by emphasizing the importance of technology in contributing to financial 

independence for individuals who have disabilities. 

 
513

October 18, 2017 

Mr. Keefer introduced an additional panel member, Susan Tachau, Chief Executive Officer for 

Pennsylvania Assistive Technology Foundation (“PATF”). He opened his presentation by 

explaining how Ms. Tachau helped educate Bryn Mawr Trust Company about the unique 

financial needs of individuals who have disabilities and how Bryn Mawr Trust Company 

partnered with PATF to develop financial products in response to those unique needs. The loan 

program that was developed for individuals who have disabilities provided financial education 

during the application process, below-market loan rates, no fees, and enhanced underwriting. 

Mr. Poluch informed the Committee that the loan program provided loans to individuals in every 

county in the state of Pennsylvania. Mr. Poluch acknowledged that the program was a 

Community Reinvestment Act (“CRA”) opportunity for the bank, and suggested that if other 

banks were presented with this perspective, they would take the time to consider the program. 

He also recommended Cents and Sensibility, a guide to money management that is published by 

PATF. 

 Member Boston shared that it was not until he attended an event on the Americans with 

Disabilities Act that he really for the first time began to understand economic inclusion as it 

relates to people with disabilities, as well as the income gap and wealth gap in communities who 

have disabilities. He also emphasized that the FDIC, Chase, Citi, and all the banks who are 

working to help individuals who have disabilities should be proud of what they are 

accomplishing. 

 Discussion followed regarding financial education and financial empowerment for 

individuals who have disabilities. 

Mr. Stokes then announced that the meeting would briefly recess. Accordingly, at 2:17 

p.m., the meeting stood in recess. 

*****

The meeting reconvened at 2:29 p.m. that same day, at which time, Keith Ernst, Associate 

Director, DCP, and moderator of the panel on “Neighborhood Access to Bank Branches – Report 

Update,” stated that the next presentation addressed vulnerable residents’ population’s access to 

bank branches across all urban areas in the United States. Mr. Rengert opened his presentation 

by explaining that FDIC researchers developed the Locally-Defined Distance Threshold (“LDT”) 

to identify areas (or census tracts) with lower access to bank branches relative to other areas 

within the same metropolitan area. He pointed out that, although the number of bank branches 

had declined in recent years, the household survey demonstrated that consumer use of bank 

branches remained high, particularly among certain groups of consumers. Those consumer 

groups included lower income consumers, adults with lower educational attainment, older 

consumers, and Spanish-speaking populations. Mr. Rengert shared research findings that 

indicated black and Hispanic survey respondents were about as likely as all respondents to rely 

on bank tellers for account access; however, black and Hispanic households were substantially 
514

October 18, 2017 

more likely to report being unbanked or underbanked. He provided census data and research 

findings for a variety of metropolitan areas, to include New York, New York; Philadelphia, 

Pennsylvania; Chicago, Illinois; Detroit, Michigan; Dallas, Texas; Washington, D.C.; Los 

Angeles, California; and Atlanta, Georgia. Mr. Rengert closed his presentation by identifying 

possible next steps, such as developing a web-based application to share maps and results for all 

Metropolitan Statistical Areas (“MSAs”), investigating spatial clusters of lower-access areas, 

incorporating locally generated data and knowledge, and identifying strategies that banks are 

using or could use to serve vulnerable populations in lower-access tracts. A question and answer 

period followed and Committee members thanked the panel for the detailed level of data. 

Chairman Gruenberg thanked the panelists for their presentations and thanked the 

Committee members for their service on this Committee. He observed that the contributions the 

Committee members have made to the FDIC and to the work in this area have been invaluable. 

Chairman Gruenberg stated this was probably his last meeting as Chairman and that it was his 

hope that the next FDIC Chairman continues with the Committee on Economic Inclusion. He 

noted that as soon as the new Chairman is announced, this will certainly be among the first issues 

he discusses with that person. 

*****

 There being no further business, the meeting was adjourned at 3:19 p.m. 

 _____________________________ 

 Robert E. Feldman 

 Executive Secretary 

Federal Deposit Insurance Corporation 

And Committee Management Officer 

FDIC Advisory Committee on Economic Inclusion 
Minutes

of

The Meeting of the FDIC Advisory Committee on Economic Inclusion 

of the

Federal Deposit Insurance Corporation 

Held in the Board Room 

Federal Deposit Insurance Corporation Building 

Washington, D.C. 

Open to Public Observation 

October 18, 2017 – 9:00 A.M.

I hereby certify that, to the best of my knowledge, the attached 

minutes are accurate and complete. 

________________________________ 

Martin J. Gruenberg 

Chairman 

Board of Directors 

Federal Deposit Insurance Corporation