2011 FDIC

Survey of Banks’ 

Efforts to Serve 

the Unbanked 

and Underbanked

December 2012

Federal Deposit 

Insurance Corporation
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  • 

Table of Contents

I. Executive Summary ...........................................................................................................................................................4

II. Background and Objectives ............................................................................................................................................10

2011 Bank Survey Details and Respondent Profile..........................................................................................................10

MSA and LMI Geographies..........................................................................................................................................10

Analysis and Statistical Significance ..............................................................................................................................11

Comparability to Prior Results.......................................................................................................................................11

III. Marketing and Retail Strategies......................................................................................................................................12

3.1 Marketing and Specialized Product Development.....................................................................................................12

3.2 Effective Marketing Channels..................................................................................................................................12

3.3 Effective Retail Strategies........................................................................................................................................12

3.3.1 Automated Telephone Banking.............................................................................................................................12

3.3.2 Multilingual Staff.................................................................................................................................................13

3.3.3 Off-Premise ATM Locations..................................................................................................................................13

3.3.4 Mobile Banking ..................................................................................................................................................13

3.4 Partnerships to Promote Checking or Savings Account Products.................................................................................13

IV. Characteristics of Basic Deposit Products.........................................................................................................................14

4.1 Basic or Entry-Level Checking Account Characteristics..............................................................................................14

4.2 Basic Savings Account Characteristics .....................................................................................................................17

4.3 Account Opening Considerations............................................................................................................................17

V. Auxiliary Products..........................................................................................................................................................19

5.1 Auxiliary Products for Basic Accountholders and Noncustomers................................................................................19

5.2 Provision of Auxiliary Products by MSA Concentration of Branches...........................................................................21

5.3 Auxiliary Products Offered at ATMs or Kiosks..........................................................................................................21

5.4 Network-Branded Reloadable Prepaid Cards...........................................................................................................21

5.5 Nontraditional Forms of Identification Accepted for Check Cashing...........................................................................21

5.6 Unsecured Personal Loans......................................................................................................................................22

VI. Financial Education and Outreach .................................................................................................................................23

6.1 Types of Financial Education and Outreach.............................................................................................................23

6.2 Locations for Financial Education and Outreach.......................................................................................................23

6.3 Financial Education and Outreach by Branch Location .............................................................................................23

VII. Potential Challenges to Offering Financial Products and Services.....................................................................................24

7.1 Bank Business Challenges.......................................................................................................................................24

7.2 Product-Related Challenges ....................................................................................................................................25

7.3 Regulatory Challenges............................................................................................................................................26

VIII. Opportunities for Banks ...............................................................................................................................................27

Appendix A - Detailed Tables............................................................................................................. Published separately

Appendix B - Survey Methodology...................................................................................................... Published separately
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. 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

II. Background and 

Objectives

Access to a basic bank account and financial services are 

fundamental building blocks for families seeking to establish 

a solid financial foundation and to pursue opportunities for 

asset building and wealth accumulation over time. Banks 

provide individuals and families with the opportunity to 

safely and effectively conduct transactions, save, borrow, 

invest, and build a credit record. According to the 2011 

FDIC National Survey of Unbanked and Underbanked 

Households, more than 34 million Americans are unbanked 

or underbanked and lack access to banks or are not fully 

participating in the mainstream financial system.3

The Federal Deposit Insurance Corporation (FDIC) is 

committed to ensuring that consumers have access to basic 

banking and other financial products and services as well 

as to developing high quality, relevant data about 

unbanked and underbanked households and factors that 

may hinder them from fully utilizing the mainstream financial system. As part of this commitment, the FDIC 

published its first nationwide survey of FDIC-insured 

depository institutions (Bank Survey) to assess their efforts 

to expand financial services to unbanked and underbanked 

individuals and families in 2009. This effort was the first of 

its kind at the national level.4

The survey was mandated by Section 7 of the Federal 

Deposit Insurance Reform Conforming Amendments Act 

of 2005. The Act requires that the FDIC survey 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. 

In designing this survey, the FDIC sought to provide information that would inform efforts to serve unbanked and 

underbanked individuals. The general objectives of the 

survey are as follows:

• Identify and quantify the extent to which insured 

depository institutions reach out to, serve, and seek to 

meet the banking needs of unbanked and underbanked 

individuals and households; 

3 The 2011 FDIC National Survey of Unbanked and Underbanked Households is available at http://www.economicinclusion.gov. Unbanked households do not have a checking account or a savings account with an 

insured depository institution. In contrast, underbanked households have 

a checking or a savings deposit account but also obtain financial products and services from nonbank, alternative financial service providers.

4 The findings are available in the report, FDIC Survey of Banks’ Efforts to 

Serve the Unbanked and Underbanked, February 2009, at http://economicinclusion.gov.

• Identify challenges affecting the ability of insured 

depository institutions to serve unbanked and underbanked individuals and households; and 

• Identify strategies that insured depository institutions 

used to offer financial products and services to 

unbanked and underbanked individuals and 

households. 

2011 Bank Survey Details and Respondent Profile

The Bank Survey was voluntary and consisted of an 

Internet-based questionnaire administered to a nationally 

representative random stratified sample of 707 bank headquarters, with 567 banks responding to the survey.5

 For 

the analysis, banks are grouped into one of three asset size 

categories listed in Figure 2.1 below.6 Results reported for 

“all banks” are weighted to achieve representative proportions of the three asset size groups. 

Largest 25Banks Midsize Banks Smallest Banks

Asset Size Greater than 

$38 Billion

$1 Billion to Less 

than $38 Billion 

Less than 

$1 Billion 

Share of Total Bank 

Assets 70% 18% 12 %

Share of Total 

Branches 43% 28% 29%

Numberof Banks in 

Survey Sample 25 282 400

Number of 

Respondent Banks 25 225 317

Share of Respondent 

Banks in Sample 4% 40% 56%

Response Rate 100% 79. 8% 79. 3%

Sources: The FDIC Institution Directory (March 2012), second quarter 2011 FDIC Call Reports, and Gallup, Inc

Figure 2.1: Summary of Bank Headquarters

Respondent Information By Bank Asset Size

MSA and LMI Geographies

Branch location information was used to categorize banks 

by their presence in metropolitan statistical areas (MSAs) 

and in low- and moderate-income (LMI) communities. 

MSAs are geographies identified by the Office of 

Management and Budget that have at least one urban area 

with a population of 50,000 or more and surrounding areas 

that are economically associated with the core urban area. 

Inclusion or exclusion from an MSA does not necessarily 

indicate whether a county is rural in nature, though counties that are not included are, by definition, not associated 

5 The proportion of branches reported for each bank grouping was 

derived from the list of branches associated with the headquarters 

universe and that were active as of March 14, 2012. The FDIC retained 

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

the survey results and reported aggregated results to the FDIC.

6 Bank asset size was determined from the second quarter 2011 FDIC Call 

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

with a highly-populated urban area.7 LMI geographies are 

based on a comparison of the census tract level median 

family income to the larger MSA/Metropolitan Division 

(MSA/MD) median family income. A geography is designated as an LMI area if the census tracts have a median 

family income that is less than 80 percent of the MSA/MD 

median family income.8

Banks were identified as having a relatively high concentration of branches in MSA communities (high-MSA) when 

the share of branches in MSAs was greater than or equal to 

75 percent and a low concentration or branches in MSA 

communities (low-MSA) when the share of branches in 

MSAs was less than 75 percent. High-LMI banks have 33 

percent or more of their branches in LMI communities, and 

low-LMI banks have less than 33 percent of branches in 

LMI areas.9

All of the largest banks had relatively high concentrations 

of branches in MSA areas (high-MSA) and outside of LMI 

communities (low-LMI). This compares with two-thirds of 

midsize banks with relatively high concentrations of 

branches in MSAs (high-MSA) and 20 percent with 

concentrations in LMI communities (high-LMI), while just 

under half of the smallest banks were considered high-MSA 

banks and 29 percent high-LMI. 

Figure 2.2: Respondent Banks by Branch Distribution 

in LMI areas and MSAs by Asset Size

Branch Distribution

All 

Banks

%

Greater 

than $38 

Billion

(Largest)

%

$1 Billion 

to Less 

than $38 

Billion 

(Midsize)

%

Less than 

$1 Billion 

(Smallest)

%

High-LMI 

(One-Third or More of Branches in 

LMI Areas)

29 0 20 29

Low-LMI

(Less than One-Third of Branches in 

LMI Areas)

71 100 80 71

High-MSA

(Three-Quarters or More of Branches in 

MSAs)

50 100 67 48

Low-MSA

(Less than Three-Quarters of Branches 

in MSAs)

50 0 33 52

Note: All respondents are included. 

7 Detailed information on the update of statistical area definitions is 

available at http://www.whitehouse.gov/sites/default/files/omb/assets/

bulletins/b10-02.pdf. 8 This report follows conventions detailed by the Federal Financial Institutions Examination Council. More information is available on how income 

geography designations are calculated at http://www.ffiec.gov/census/

censusInfo.aspx. 9 Branch location data was taken from the FDIC’s Institution Directory file 

as of March 14, 2012. The high-LMI criterion of 33 percent of a bank’s 

branches in an MSA was the 75th percentile value for all banks in existence at this time. The high-MSA criterion of a bank having 75 percent of 

its branches in an MSA tract is roughly the median value. (The actual 

median value was 66.7 percent, while the 52nd percentile is 75 percent.) 

Although somewhat arbitrary, these categorizations are reasonable, and 

also were chosen to ensure that the identity of survey respondents 

remained protected. 

Analysis and Statistical Significance 

For each of the topics discussed in this report, a small 

proportion of respondents did not provide an answer to 

the relevant question in the survey instrument. We generally do not discuss patterns of “no response” and do not 

include them in the calculations of descriptive statistics 

such as proportions, means, and medians, unless otherwise 

specified in the report. Each table in Appendix A includes 

a non-response rate relevant to the analysis in that table. 

Displayed non-response rates include both respondents 

that did not answer the question and respondents that 

were not presented the question since, for example, previous responses on the questionnaire indicated that the 

question was not relevant to the bank. 

Unless otherwise indicated, differences discussed in this 

report are significant at least at the 10 percent level. That 

is, if there was no actual difference in the underlying 

populations being compared, the probability of obtaining 

sample estimates with the observed difference or a larger 

difference would be no more than 10 percent, and could 

be considerably less. For additional details on the survey 

and its methodology, see Appendix B to this report. 

Comparability to Prior Results 

The FDIC extensively revised the 2009 Bank Survey to 

create the 2011 Bank Survey instrument. Questions were 

revised and streamlined to improve the questionnaire and 

promote strong response rates. The survey also was 

converted from a paper-based to an Internet-based instrument, which provided greater convenience for the 

respondent. These improvements and revisions make it 

largely impossible to compare results from the two surveys. 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

III. Marketing and Retail 

Strategies

A substantial proportion of banks reported developing specialized products, services, or programs customized to meet the 

needs of unbanked and underbanked consumers. Community 

outreach collaborations were the most frequently cited marketing channel and automated telephone banking was the most 

common retail strategy used by banks. Close to one-half of all 

banks maintained partnerships with organizations to promote 

opening checking and savings accounts. 

3.1 Marketing and Specialized Product 

Development

Thirty-seven percent of all banks said that they actively 

marketed to unbanked and underbanked consumers. 

Two-thirds of the largest banks, 43 percent of midsize 

banks, and 36 percent of the smallest banks reported 

actively marketed to underserved consumers. Almost 43 

percent of all banks reported developing specialized products and services for underserved consumers, with 92 

percent of the largest banks, 60 percent of midsize banks, 

and 41 percent of the smallest banks reported having done 

so. 

3.2 Effective Marketing Channels 

The survey asked banks to rank the most effective channels (e.g., community outreach collaborations with 

community organizations, advertising in newspapers and 

other print media, and TV or radio advertising) used to 

market products and services to unbanked and underbanked consumers. 

Thirty-nine percent of all banks that actively marketed to 

unbanked and underbanked consumers reported community outreach collaborations with community groups, 

nonprofits, and government agencies or other organizations as the most effective marketing channel. By bank 

asset size, all three groups selected this option as the most 

effective, with narrow majorities of the largest and midsize 

banks and almost 37 percent of the smallest banks selecting community outreach collaborations as the most 

effective way to reach unbanked and underbanked 

consumers. 

The second most commonly selected choice for the single 

most effective marketing channel among banks that 

actively marketed to the underserved was advertising in 

print media, with 13 percent of the largest banks, 19 

percent of midsize banks, and 31 percent of the smallest 

banks choosing this as most common second option. 

6 

29 

1 

8 7 

39 

25 

13 

6 

0 

6 

50 

5 

19 

0 

10 

4 

55 

6 

31 

1 

8 7 

37 

0 

10 

20 

30 

40 

50 

60 

TV or radio 

advertising 

Print 

advertising 

Email or social 

media marketing 

Direct mail Billboard 

advertising 

Community 

outreach 

Percenage of Banks Note: Proportions are calculated based on respondents that actively marketed to the unbanked and underbanked and 

that also answered the question about most effective marketing channels.

Figure 3.1: Most Effective Marketing Channels 

by Asset Size (Percent)

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

3.3 Effective Retail Strategies 

Banks were asked if they used specific retail strategies to 

make their branches more welcoming or convenient for 

consumers. For the purpose of this question, banks were 

asked to respond about all customers and not specifically 

about unbanked or underbanked consumers. The retail 

strategies included nontraditional locations (e.g., community centers or supermarkets); off-premise ATMs in retail 

establishments or other accessible locations; nontraditional branch format or design (e.g., casual lobby décor); 

extended banking hours on weekday evenings, Saturday 

afternoons, or Sundays; multilingual staff; online 

(Internet) banking; mobile (cell phone) banking; and 

automated telephone banking. In general, the most 

frequently chosen retail strategies were automated telephone banking, multilingual staff, and off-premise ATM 

locations. 

The survey further explored the effectiveness of each retail 

strategy by asking banks to rate the effectiveness of each 

in terms of developing a relationship with unbanked or 

underbanked consumers. Each strategy was rated on a 

four-point scale from “very effective” to “not effective at 

all” and respondents could also reply that they did not 

know the effectiveness of the strategy for the stated 

purpose. The effectiveness rating for each of the most 

frequently chosen strategies is discussed below. 

3.3.1 Automated Telephone Banking

A relatively large proportion of institutions, regardless of 

size, indicated that they used an automated telephone 

banking retail strategy for improving customer experiences. More specifically, 62 percent of banks stated that 

they used the strategy, including 96 percent of the largest 

banks, 87 percent of midsize banks, and almost 60 percent 

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

The effectiveness rating of the automated telephone banking retail strategy in developing a relationship with 

underserved consumers varied little among banks of different sizes. Regardless of asset size, almost half of the 

institutions rated this strategy as very effective or 

effective. 

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

Figure 3.2: Retail Strategies by Asset Size (Percent) 

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

10 

40 38 37 

43 

8 

28 

62 64 

88 

56 

76 

96 

48 

88 

96 

39 

69 

43 

67 

81 

18 

57 

87 

8 

38 37 35 

40 

7 

26 

60 

0 

20 

40 

60 

80 

100 

120 

location 

Non-traditonal Off-premise 

ATMs 

Non-traditional 

branch format/

design 

Extended 

banking 

 hours 

Multilingual staff 

available 

Online 

(Internet) 

banking 

Mobile 

(cell phone)

 banking 

Automated 

(IVR) telephone 

banking 

Percentage of Banks 

3.3.2 Multilingual Staff

The availability of multilingual staff was the second most 

frequently chosen retail strategy, selected by 43 percent of 

banks. Ninety-six percent of the largest banks reported 

using this strategy to make the bank more welcoming or 

convenient for customers and close to 77 percent rated 

this strategy as very effective or effective. Eighty-one 

percent of midsize banks chose this strategy and two-thirds 

rated it as very effective or effective. For the smallest 

banks, 40 percent employed multilingual staff, and of 

those institutions 61 percent said that this strategy was 

very effective or effective for establishing relationships 

with the underserved market. 

3.3.3 Off-Premise ATM Locations

The availability of off-premise ATM locations was the 

third most frequent retail strategy, selected by 40 percent 

of banks. Eighty-eight percent of the largest banks choose 

off-premise ATMs as a retail strategy for making the bank 

more convenient and welcoming. Of these institutions, 

more than one-third rated this strategy as very effective or 

effective. Sixty-nine percent of midsize banks and 38 

percent of the smallest banks selected this strategy, and 42 

percent of each group rated this strategy as very effective 

or effective. 

3.3.4 Mobile Banking

Mobile banking appears to be a more well-established 

retail strategy among larger institutions. Eighty-eight 

percent of the largest banks used this retail strategy to 

make banking more convenient or welcoming. Overall, 28 

percent of all banks used this strategy, with 57 percent of 

midsize banks and 26 percent of the smallest banks using 

this strategy. 

About one-third of the largest and midsize banks rated 

mobile banking as a very effective or effective strategy for 

developing relationships with unbanked and underbanked 

consumers, while 18 percent of the smallest banks rated 

this strategy in the same way. 

Of the retail strategies discussed in this report, mobile 

banking had the highest proportion of respondents (34 

percent) indicate that they did not know enough to assess 

the effectiveness of the strategy for meeting the needs of 

the underserved. This proportion of “don’t know” was 

much greater than, for example, the 13 percent of respondents that could not assess the effectiveness of off-premise 

ATMs or the 7 percent “don’t know” response rate associated with multilingual staff. 

3.4 Partnerships to Promote Checking or Savings 

Account Products 

The survey asked banks whether they maintained partnerships with organizations (e.g., school districts, volunteer 

income tax assistance (VITA) sites, and faith/communitybased organizations) to promote checking or savings 

accounts. About half of all banks, promoted checking (49 

percent) and savings (50 percent) accounts through partnerships, including roughly eight in ten of the largest 

banks, three-quarters of midsize banks, and slightly less 

than one-half of the smallest banks. 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

IV. Characteristics of Basic 

Deposit Products

On the most basic or entry-level checking account, almost half 

(48 percent) of all banks required a minimum opening balance 

of $100 or more. Nearly two-thirds of banks charged no 

monthly maintenance fee, though one in five charged more 

than $3 per month on accounts without direct deposit. Sixtyfive 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. The largest banks were the most likely to charge monthly maintenance 

fees in excess of $3 on accounts without direct deposit (72 

percent did so), but 64 percent of the largest banks charged no 

fee if the account had direct deposit. Median NSF and overdraft fees were both $28, though higher (median of $35) for 

the largest banks. 

Among banks that required a minimum opening balance for a 

basic savings account, the median opening balance required 

was $100. Most banks had a zero monthly maintenance fee if 

the minimum average balance requirement was met, which was 

also $100, at the median. If the minimum average balance 

requirement was not met, the median monthly fee was $2.50. 

Opening balance requirements tended to be lower at the largest 

banks (median of $25), but the amount required to be held in 

savings to avoid a maintenance fee (median average balance of 

$300) and the fees charged for accounts with less than this 

amount (median of $4) tended to be greater at these institutions. A substantial majority of banks offered one of the 

following specialty savings products: Individual Development 

Accounts (IDAs), specialized savings clubs, workplace-based 

savings, or youth (minor) savings accounts, with the largest 

banks offering IDAs and workplace-based savings accounts 

more frequently. 

4.1 Basic or Entry-Level Checking Account 

Characteristics

Bank respondents were asked to describe the characteristics of a basic checking account, including the minimum 

opening balance requirement, the monthly maintenance 

fee, the minimum account balance required to avoid a fee, 

and if fees differed depending on whether the accountholder used direct deposit.10 Banks were also asked if they 

offered an electronic, card-based account as their most 

basic checking product. Finally, banks were asked to 

10 In the survey, a basic or entry-level checking or savings account was 

defined as an FDIC-insured transaction or deposit account that has the 

most basic features and tends to have the lowest minimum balance 

requirements.

describe fees for check processing, nonsufficient funds, and 

overdrafts. 

Account Opening Requirements

Nearly half of banks (48 percent) required a minimum 

initial deposit of $100 or more to open a basic checking 

account without direct deposit. By comparison, 12 percent 

of the largest banks and nearly 16 percent of both midsize 

and the smallest banks did not require a minimum balance 

to open an account without direct deposit. A greater share 

of the largest banks (36 percent) had a minimum opening 

balance requirement of between $1 and $49, compared 

with midsize banks (24 percent) and the smallest banks 

(15 percent). The median minimum opening balance 

requirement was $50 for both the largest and midsize 

banks, and $100 for the smallest banks. 

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 4.1: Minimum Opening Balance Requirement 

by Asset Size

15 

12 

16 15 16 

36 

24 

15 17 

28 

25 

17 

42 

20 

32 

43 

6 4 2 

6 

0 

5 

10 

15 

20 

25 

30 

35 

40 

45 

50 

All Banks Greater than $38 Billion 

(Largest) 

$1 Billion to Less than $38 

Billion (Midsize) 

Less than $1 Billion 

(Smallest) 

Percentage of Banks 

$0 $1-$49 $50 $100 > $100 

For most banks, whether a customer had direct deposit did 

not affect the minimum opening balance requirements. 

However, for the roughly 7 percent of banks where it 

made a difference, direct deposit reduced the required 

minimum opening balance substantially, often to zero. 

Monthly Maintenance Fees

Nearly two-thirds of banks charged no monthly maintenance fee on basic checking accounts without direct 

deposit, though 22 percent charged fees in excess of $3. 

Among banks that charged a fee, the median monthly 

maintenance fee for accounts with direct deposit was 

roughly $5 regardless of asset size; the median monthly 

maintenance fee without direct deposit was $7.50 for the 

largest banks and $5 for both midsize and the smallest 

banks. A substantial proportion of the largest banks (72 

percent) assessed a monthly maintenance fee of more than 

$3 on accounts without direct deposit, but 64 percent 

charged no fee if the account had direct deposit. Less than 

one-fourth of midsize or small banks had a monthly maintenance fee of more than $3, and most midsize (71 

percent) and small (65 percent) banks had no monthly 

maintenance fee even on accounts without direct deposit. 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

Figure 4.2: Monthly Maintenance Fees for Basic or Entry-Level 

Checking Accounts by Asset Size (Percent) 

65 

10 

22 

72 

8 

17 20 

4 

72 

64 

0 

36 

71 

5 

23 

79 

3 

17 

65 

11 

22 

71 

9 

17 

0 

10 

20 

30 

40 

50 

60 

70 

80 

90 

$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 Note: Proportions are calculated based on all banks.

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

Minimum Account Balance Requirements

Most banks did not require customers to maintain a minimum account balance on a basic checking account 

without direct deposit in order to avoid a low-balance fee. 

About three-quarters of midsize banks, two-thirds of the 

smallest banks, and 44 percent of the largest banks had no 

minimum account balance requirement. Without direct 

deposit, the median minimum account balance requirement to avoid a fee among banks that had a minimum 

account balance requirement was $1,500 for the largest 

banks, $500 for midsize banks, and $325 for the smallest 

banks. With direct deposit, these institutions reported that 

the median minimum was $1,000 for the largest banks, 

$500 for midsize banks, and $300 for the smallest banks. 

Figure 4.3: Minimum Account Balance Required to Avoid 

Low-Balance Fees by Asset Size (Percent) 

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

68 

2 

27 

71 

1 

24 

44 

4 

48 52 

8 

36 

74 

6 

18 

79 

4 

15 

67 

1 

28 

71 

1 

25 

0 

10 

20 

30 

40 

50 

60 

70 

80 

90 

$0 $1 to $25 > $25 $0 $1 to $25 > $25 

Without Direct Deposit With Direct Deposit 

Percentage of Banks Note: Proportions are calculated based on all banks.

Direct deposit had a minor impact on minimum account 

balance requirements for the largest banks. Although 52 

percent of the largest banks offered a zero minimum 

balance on accounts with direct deposit, 28 percent had a 

minimum balance requirement of more than $500. 

Availability of Electronic Card-Based Accounts

Among all banks, only 21 percent offered electronic 

(card-based) accounts as their most basic account product. 

Even fewer—8 percent of the largest banks, 3 percent of 

midsize banks, and less than 1 percent of the smallest 

banks—offered a strictly card-based, electronic account 

(i.e., an account that does not allow at least some paper 

checks to be written). Although the number of banks 

offering a check-free, card-based, electronic account is 

small, the average minimum needed to open an account 

and the average monthly maintenance fees are lower for 

these accounts than for traditional checking accounts with 

a check writing feature.11 While not conclusive, these 

findings provide some evidence to suggest that the fees are 

less for lower-cost accounts such as check-free, card-based, 

electronic accounts. 

Figure 4.4: Electronic Card-Based Accounts 

by Asset Size (Percent) 

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

21 

1 

12 

8 

16 

3 

21 

1 

0 

5 

10 

15 

20 

25 

Card-Based with Checks Card-Based without Checks 

Asset Tier 

Percentage of Banks Note: Proportions are calculated based on respondents and non-respondents. 

Check Processing Fees

Most banks, regardless of asset size, did not charge a peritem fee on paper checks. In each asset category, over 80 

percent of banks had no per-item fee on paper checks. 

When a per-item check fee was charged, it was generally 

small. The median fee among those assessing one was 

$0.35 for the largest banks, $0.50 among midsize banks, 

and $0.20 among the smallest banks. 

Nonsufficient Funds (NSF) Fees

Nonsufficient funds (NSF) fees varied by institution size, 

with larger banks charging higher fees. The overall average NSF fee was $26.58, and the median was $28.00. The 

median NSF fee among the largest banks was $35, 

compared with $32 for midsize banks and $27 for the 

smallest banks. A greater share of the largest banks 

charged an NSF fee of more than $30; over 70 percent of 

11 These findings hold for traditional checking accounts, regardless of 

whether direct deposit is used. It also is worth noting that the median 

value for the minimum needed to open an account ($100) and the median 

maintenance fee ($5) is the same for both types of basic, entry-level 

accounts discussed here even as the mean averages vary.
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

the largest banks, 53 percent of midsize banks and 15 

percent of the smallest banks charged an NSF fee of more 

than $30. 

3 

43 

33 

18 

12 16 

0 

72 

2 

13 

28 

53 

3 

45 

33 

15 

0 

10 

20 

30 

40 

50 

60 

70 

80 

No Fee $1 to $25 Fee $26 to $30 Fee More Than $30 

Percentage of Banks Note: Proportions are calculated based on all banks.

Figure 4.5: Nonsufcient Funds Fee 

by Asset Size (Percent)

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

Banks with a greater share of branches in MSAs (highMSA) also charged higher NSF fees, with 24 percent of 

high-MSA banks charging fees above $30 compared with 

13 percent of low-MSA banks. These patterns were 

evident across the three asset groups. For example, 20 

percent of the smallest banks with a high-MSA proportion 

charged NSF fees above $30, compared with 11 percent of 

the smallest banks with a low-MSA proportion. For 

midsize banks, 57 percent of high-MSA midsize banks 

charged NSF fees above $30, compared to 47 percent of 

low-MSA midsize banks. 

Automated and Non-Automated Overdraft Programs

Regardless of asset size, a large majority of banks offered 

an overdraft payment program, as well as an alternative to 

an overdraft program, such as a linked account or line of 

credit. Roughly 90 percent of both the largest, midsize, 

and small banks offered automated or non-automated 

overdraft programs. Among banks that responded to this 

question, automated overdraft programs (ODPs) were 

more common at larger institutions. Roughly 70 percent 

of the largest institutions had an automated ODP, while 

54 percent of midsize and 32 percent of the smallest banks 

had one.12 Most banks (92 percent of the largest banks, 94 

percent of midsize banks, and 85 percent of the smallest 

banks) offered an alternative to an ODP, in the form of 

either a linked-account program or a line of credit. 

Overdraft Fees

As with NSF fees, ODP fees generally varied by bank size 

and MSA branch share, with larger banks and banks with 

a higher share of branches in MSAs charging higher fees. 

12 Automated overdraft coverage is a payment program that typically (but 

not always) relies on computerized decision-making, and uses pre-established criteria to pay or return specific items. There is little to no discretion given to bank employees, and no case-by-case bank employee 

decision-making with respect to an individual customer or item.

Overdraft fees were generally higher for the largest banks 

than for midsize or the smallest banks. Roughly 68 percent 

of the largest banks, 52 percent of midsize banks, and 14 

percent of the smallest banks charged overdraft fees of 

more than $30. The average overdraft fee was $26.45, and 

the median fee was $28.00. The overdraft fee was higher 

at larger banks. For example, the median overdraft fee was 

$35 for the largest banks, $32 for midsize banks, and $27 

for the smallest banks. 

As with NSF fees, estimated overdraft fees were slightly 

higher among banks with a larger proportion of branches 

in MSAs (high-MSAs). For example, 18 percent of the 

smallest banks with a high-MSA concentration charged 

NSF fees above $30, compared with 10 percent of the 

smallest banks with a low-MSA concentration. For 

midsize banks, 57 percent of those with a high-MSA 

concentration charged NSF fees greater than $30, 

compared to 41 percent of midsize banks with a low-MSA 

concentration. 

Overdraft fee patterns were similar to NSF fee patterns: in 

the majority of cases, banks charged the same fee for NSF 

and ODP. Indeed, ODP and NSF fee amounts were identical for 78.5 percent of all banks. A small proportion of 

banks (7.5 percent) charged ODP fees that differed from 

NSF fees. Similarities among the remaining banks (13.8 

percent) were unknown or not applicable because the 

ODP or NSF fee was unknown or the bank did not cover 

overdrafts. 

Funds Availability

Based on a hypothetical check of $2,500 or less made 

payable to an established bank customer, respondents were 

asked how quickly in terms of number of business days the 

full amount of funds would ordinarily be available, in the 

case of the most basic or entry-level checking account. A 

majority of banks made funds available either on the same 

business day or on the next business day, regardless of 

check type. However, a lower proportion of the largest 

banks made funds available on the same day. 

Banks reported their funds availability policies on check 

amounts of $2,500 or less for four alternative types of 

checks: “on-us” checks, payroll checks, personal checks, 

and government checks.13 More midsize and small banks 

made funds available on the same business day for 

personal checks than did the largest banks. Specifically, 

29 percent of the smallest banks, 14 percent of midsize 

banks, and 4 percent of the largest banks made funds 

available on the same business day. The percentages were 

even higher for other check types.

13 An “on-us” check is a check presented for payment at the same institution on which the check is drawn.
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

Banks with a larger share of branches in MSAs (highMSA) were less likely to make funds available on the 

same day. For example, among the smallest banks with a 

high-MSA concentration, only 30 percent made funds 

from a payroll check available on the same day, compared 

with 54 percent of the smallest banks with a low-MSA 

concentration. This finding was less pronounced for 

midsize banks: 21 percent of midsize banks with a highMSA concentration made funds from a payroll check 

available on the same day, compared to 27 percent of 

midsize banks with a low-MSA concentration. 

4.2 Basic Savings Account Characteristics

Bank respondents were asked to describe the characteristics of basic or entry-level savings accounts (basic savings 

accounts), including the minimum opening balance 

requirement, the monthly maintenance fee, the minimum 

account balance requirement to avoid a fee, and whether 

automatic saving is an option with the most basic 

account. Banks were also asked if they offered specialty 

savings products, such as Individual Development 

Accounts (IDAs), specialized savings clubs, workplacebased savings, or youth (minor) savings accounts. 

Account Opening Requirements

The median minimum opening balance for a basic savings 

account was $100. The median opening balance requirement was $25 at the largest banks and $100 among 

midsize and small banks. Sixty percent of the largest banks 

required a minimum opening balance of $25 or less, while 

roughly one-third of midsize and the smallest banks 

required a minimum opening balance of $25 or less. 

Minimum Account Balance Requirements

The median minimum average account balance on the 

most basic savings accounts to avoid a fee was $100. 

However, an estimated 76 percent of the largest banks, 42 

percent of midsize banks and 21 percent of the smallest 

banks had a minimum average balance requirement of 

over $100 on their most basic savings account. Eight 

percent of the largest banks, 28 percent of midsize banks, 

and 37 percent of the smallest banks had a minimum average balance requirement of $25 or less. 

Monthly Maintenance Fees

Many banks had a zero monthly maintenance fee on their 

most basic savings account if the minimum average 

balance requirement was met. Roughly 64 percent of the 

largest banks, 45 percent of midsize banks, and 40 percent 

of the smallest banks said they did not charge a fee if the 

minimum balance was met. While most banks did not 

charge more than $3 for the monthly maintenance fee if 

the minimum balance was met, a somewhat greater 

proportion of the largest banks (16 percent) did so than 

midsize (11 percent) and the smallest (9 percent) banks. 

If the minimum average balance requirement was not met, 

the median monthly maintenance fee charged by banks 

was $2.50. In these circumstances, the median fee charged 

by the largest banks was $4 on their basic savings account 

product. Most midsize and small banks did not charge a 

fee or charged a fee below $3 in these circumstances. If 

the minimum average balance was not met, 68 percent of 

the largest banks, 28 percent of midsize banks and 18 

percent of the smallest banks assessed a monthly fee of 

more than $3. 

Automatic Savings Options

Most banks (75 percent) offered an automatic saving 

option without a fee on their most basic savings account 

product. About 92 percent of the largest banks, 80 percent 

of midsize banks, and 75 percent of the smallest banks 

offered this option for free. None of the largest banks that 

offered automatic saving charged a fee for this feature, 

while 3 percent of midsize banks and 4 percent of the 

smallest banks did. 

Specialty Savings Products

A substantial 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, with the largest banks offering IDAs and 

workplace-based savings more frequently. Most banks 

offered youth savings accounts (82 percent), regardless of 

asset size. A greater proportion of the largest banks offered 

IDAs (46 percent) than did midsize (20 percent) or the 

smallest (2 percent) banks. A greater proportion of the 

largest banks also offered workplace-based savings (52 

percent) than did midsize (31 percent) or the smallest (7 

percent) banks. 

4.3 Account Opening Considerations

In addition to questions regarding various account opening requirements, the survey also asked whether banks 

accepted nontraditional forms of ID from prospective 

customers seeking to open a new deposit account. In addition, respondents explained how they address negative 

information that is obtained during the account screening 

process regarding potential customers. 

Nontraditional Forms of Identification

A majority of banks accepted a non-US passport or some 

other nontraditional form of ID from prospective customers. Among banks that responded, 58 percent overall, 

including ninety-six percent of the largest banks, 74 

percent of midsize banks and 56 percent of the smallest 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

banks accepted a non-US passport. Forty percent accepted 

ID from a foreign consulate, including 92 percent of the 

largest banks, 53 percent of midsize banks, and 38 percent 

of the smallest banks. Regardless of asset size, roughly 

three out of four banks accepted an Individual Taxpayer 

ID Number (ITIN) instead of a Social Security Number at 

account opening. 

Figure 4.6: Nontraditional Forms 

of Identication (Percent)

58 

96 

75 

56 

40 

92 

53 

38 

73 75 

85 

72 

0 

10 

20 

30 

40 

50 

60 

70 

80 

90 

100 

All Banks Greater than $38 Billion 

(Largest) 

$1 Billion to Less than 

$38 Billion (Midsize) 

Less than $1 Billion 

(Smallest) 

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

Accept Non-US Passport Accept Other Foreign Consultate ID Accept ITIN 

Application Screening Procedures

Financial institutions may consult a credit reporting 

agency or another third-party credit or consumer transaction reporting database during the application screening 

process. If the application screening process returned 

either a negative or insufficient information outcome, 

only a small proportion of banks—less than one in four—

automatically rejected the application, as opposed to 

reviewing the application at the local branch or some 

other designated location. Most banks, regardless of size, 

reviewed the application where it was received. 

With respect to checking account applications, regardless 

of bank size, roughly two-thirds of banks cited “negative 

screening hit due to prior account closure or mismanagement” as the most common reason for denying an 

application. The second most common reason was “insufficient identification,” cited by 18 percent of all banks. 

Results are similar for savings account applications. 

Figure 4.7: Most Common Reason for Checking 

Account Application Denial (Percent) 

18 

65 

3 7 2 

13 

71 

4 0 0 

15 

71 

7 3 1 

18 

65 

3 7 2 

0 

10 

20 

30 

40 

50 

60 

70 

80 

Insuf cient ID Negative Screening 

Hit, Prior Account 

Mismanagement 

Negative Screening 

Hit, Fraud 

Insuf cient or 

Negative Credit 

History 

Insuf cient Initial 

Deposit 

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

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

“Second-Chance” Account Options for Customers 

Denied a Conventional Account

If an applicant does not qualify for a conventional checking account, a bank may offer a transaction account that 

provides electronic access with little, if any, check writing 

capability. The survey finds that one in five banks (21 

percent) offered a “Stepping Stone” or “Second Chance” 

account to individuals not qualified for conventional 

accounts. The proportion of banks offering these accounts 

was higher among large banks (44 percent) than midsize 

(32 percent) and the smallest banks (20 percent). 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

V. Auxiliary Products

Banks offered auxiliary financial products and services to their 

basic or entry-level accountholders and noncustomers. These 

products and services include payroll check cashing, bank or 

other official checks, money orders, domestic and international 

remittances, in-person third-party bill payment, networkbranded reloadable prepaid cards, and unsecured personal 

loans. 

The most commonly offered auxiliary products to both basic 

accountholders and noncustomers were payroll check cashing, 

bank or other official checks, and money orders. Compared to 

these commonly offered auxiliary products, domestic and international remittances were offered less frequently. Sixty-eight 

percent of banks offered domestic remittances to basic accountholders and fifty-seven percent offered international remittances 

to basic accountholders, but only 11 percent offered domestic 

remittances and 9 percent offered international remittances to 

noncustomers. Twenty-two percent of banks offered in-person 

third-party bill payment to accountholders and 9 percent 

offered this auxiliary service to noncustomers. In terms of 

network-branded reloadable prepaid cards, 23 percent of banks 

offered this basic financial services product to basic accountholders and 14 percent offered this product to noncustomers. 

Among all banks, more than one-half (56 percent) offered 

unsecured personal loans with small dollar loan features, such 

as a minimum loan amount of $2,500 or less, an APR of 36 

percent or less, a repayment period of more than 90 days, and 

streamlined underwriting. Among all banks, 88 percent offered 

unsecured personal loans. Of those banks, 43 percent reported 

that they did not set a minimum loan amount and 53 percent 

reported having a minimum low amount of $2,500 or less. 

5.1 Auxiliary Products for Basic Accountholders 

and Noncustomers 

Financial institutions were asked to indicate whether they 

offer auxiliary products to their most basic or entry-level 

accountholders (basic accountholders) or noncustomers in 

their market area. Institutions also described the fee, if 

any, they charged for a product with a hypothetical 

amount of $250. For example, respondents indicated the 

amount they charge a noncustomer to cash a $250 payroll 

check, or purchase a $250 money order, cashier’s check, or 

domestic or international remittance.14

14 Respondents were asked to provide the typical fee associated with the 

service, either in a dollar amount or as a percentage. In most cases, 

banks reported a dollar fee. For the purpose of reporting the average and 

median cost of auxiliary services, the percentage fee was multiplied by 

the hypothetical $250 auxiliary service to arrive at a dollar fee.

Official Checks (Cashier’s Checks, Bank Checks, 

E-Checks, or Other Official Checks)

For basic accountholders, the most commonly offered 

auxiliary product was an official check, such as a bank 

check, cashier’s check, or e-check. Eighty-six percent of 

banks offered official checks to basic accountholders, 

while 14 percent of banks did not.

86 96 91 86 

35 

54 

33 35 

0 

20 

40 

60 

80 

100 

120 

All Banks Greater than $38 Billion 

(Largest) 

$1 Billion to Less than $38 

Billion (Midsize) 

Less than $1 Billion 

(Smallest) 

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

To Basic Accountholders To Noncustomers 

Figure 5.1: Banks Offering Ofcial Checks (Percent)

Among banks that offered official checks, most (73 

percent) charged a fee to basic accountholders for official 

bank checks; although more than one-fourth (27 percent) 

offered bank or other official checks free of charge. Both 

the average and median official check fee was $5, 

although larger banks charged higher fees on average. 

(The median fee charged was $8 by the largest banks and 

$5 for both midsize and small banks). Ninety-six percent 

of the largest banks, 91 percent of midsize banks, and 86 

percent of the smallest banks offered official checks to 

basic accountholders. 

The majority of banks (65 percent) did not make official 

checks available to noncustomers. For the slightly more 

than one-third that did, the average fee charged was 

$6.57, and the median fee was $5.00. 

Again, a higher share of larger banks offered official 

checks to noncustomers, and, on a median and average 

basis, they charged higher fees than other institutions. 

Fifty-four percent of the largest banks sold official checks 

to noncustomers, while about one-third of midsize and 

small banks did so. The median fee charged by the largest 

and midsize banks was $7.75 and $7, respectively, and $5 

for the smallest banks. 

Check Cashing

Payroll check cashing was the second most frequently 

offered auxiliary service to basic accountholders and the 

most frequently offered service to noncustomers. Seventyone percent cashed payroll checks for basic 

accountholders, and 47 percent offered this service to 

noncustomers. 

Among banks that offered check cashing, eighty percent 

of the largest banks, 77 percent of midsize banks, and 71 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

percent of the smallest banks cashed payroll checks for 

basic accountholders. Ninety-five percent of these banks 

indicated they cashed a $250 payroll check for free, while 

5 percent charged a fee. The average fee was $5.61, and 

the median was $5.00. 

Among the 47 percent of banks that cash a payroll check 

for noncustomers, twenty-seven percent offered free 

payroll check cashing, while 73 percent charged a fee for 

this service and 53 percent did not offer it to noncustomers. The average check-cashing fee was $6.52, and the 

median fee was $5.00. 

Eighty-four percent of the largest banks, and nearly onehalf of midsize and the smallest banks offered payroll 

check cashing to noncustomers. The median fee was 

$5.00. While the proportion of banks that reported they 

were providing this service for free to non-customers may 

seem high, it may be that at least some respondents were 

referring to a subset of payroll check cashing, such as 

payroll checks drawn on the institution. 

Eighty-four percent of the largest banks, and nearly onehalf of midsize and the smallest banks offered payroll 

check cashing to noncustomers. The median fee was $5. 

00. While the proportion of banks that reported they were 

providing this service for free to non-customers may seem 

high, it may be that at least some respondents were referring to a subset of payroll check cashing, such as payroll 

checks drawn on the institution. 

Figure 5.2: Banks Offering Check Cashing (Percent) 

71 

80 77 71 

47 

84 

45 47 

0 

10 

20 

30 

40 

50 

60 

70 

80 

90 

Percentage of Banks 

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

To Basic Accountholders To Noncustomers 

All Banks Greater than $38 Billion 

(Largest) 

$1 Billion to Less than $38 

Billion (Midsize) 

Less than $1 Billion 

(Smallest) 

Money Orders

Although most banks offered official checks to basic 

accountholders, the availability of money orders was less 

prevalent. Only 68 percent of all banks offered money 

orders to basic accountholders. Of those that did offer 

money orders, 29 percent provided them for free, and 71 

percent charged a fee. The average money order fee was 

$3.06, and the median fee was $3.00 for a hypothetical 

$250 money order. Eighty-four percent of the largest 

banks, 66 percent of midsize banks, and 68 percent of the 

smallest banks offered money orders to basic 

accountholders. 

While most banks did not offer money orders to noncustomers (67 percent), 33 percent offered them for a fee. 

The average fee was $4, and the median fee was $3. 

Approximately one-half of the largest banks offered 

money orders to noncustomers (54 percent), while 26 

percent of midsize banks and one-third of small banks did. 

On average, large and midsize banks charged higher fees 

(median $5 fee) for money orders compared to the smallest banks (median $3 fee). 

Figure 5.3: Banks Offering Money Orders (Percent) 

To Basic Accountholders To Noncustomers 

68 

84 

66 68 

33 

54 

26 33 

0 

10 

20 

30 

40 

50 

60 

70 

80 

90 

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

All Banks Greater than $38 Billion 

(Largest) 

$1 Billion to Less than $38 

Billion (Midsize) 

Less than $1 Billion 

(Smallest) 

Domestic and International Remittances

Overall, banks were more likely to offer domestic remittances than international remittances to basic 

accountholders. Most banks, however, declined to offer 

either domestic or international remittances to 

noncustomers. 

Sixty-eight percent of banks offered domestic remittances 

to basic accountholders, and 57 percent offered international remittances. A slightly greater proportion of large 

(64 percent) and midsize banks (65 percent) than small 

banks (56 percent) offered international remittances but 

the offering of domestic remittances was nearly identical 

(64 percent for the largest banks, 71 percent for midsize 

banks, and 68 percent for the smallest banks). 

Fees for remittances varied depending on the type of 

remittance and the size of the financial institution. The 

median fee for basic accountholders for a $250 domestic 

remittance was $20, while the median fee for an international remittance to Mexico was $40. The largest banks 

charged lower fees for international remittances and 

slightly higher fees for domestic remittances. 

Figure 5.4: Banks Offering Remittances (Percent) 

68 

11 

57 

9 

64 

12 

64 

20 

71 

11 

65 

11 

68 

11 

56 

8 

0 

10 

20 

30 

40 

50 

60 

70 

80 

Domestic Remittances to 

Basic Accountholders 

Domestic Remittances to 

Noncustomers 

International Remittances 

to Basic Accountholders 

International Remittances 

to Noncustomers 

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

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

Remittances are rarely offered to noncustomers. Overall, 

only 11 percent of banks offered domestic remittances and 

9 percent offered international remittances to noncustomers. Twenty percent of the largest banks, 11 percent of 

midsize banks, and 8 percent of the smallest banks offered 

international remittances to noncustomers. The median 

fee for a $250 domestic remittance was $20, while the 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

median fee for an international remittance to Mexico was 

more than twice this amount. 

In-Person Third-Party Bill Payment

In-person third-party bill payments enable consumers to 

pay bills, such as utility bills, in person at the bank. These 

services are likely provided as a convenience to customers, 

but only a small proportion of banks offered them. 

Overall, 22 percent of all banks provided in-person thirdparty bill payments to basic accountholders and 9 percent 

of banks offered this product to noncustomers. Only 13 

percent of the largest banks and 18 percent of midsize 

banks offered these payments to basic accountholders, 

while 23 percent of the smallest banks offered this service. 

For basic accountholders, the average fee for these 

payments was $2.86, and the median fee was $1.00. 

Among the small proportion of banks that offered 

in-person third-party bill payments to noncustomers, the 

average fee was $1.76 and the median fee was $2.00. 

22 

13 

18 

23 

9 8 

5 

9 

0 

5 

10 

15 

20 

25 

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

Figure 5.5: Banks Offering In-Person 

Third-Party Bill Pay (Percent) 

To Basic Accountholders To Noncustomers 

All Banks Greater than $38 Billion 

(Largest) 

$1 Billion to Less than $38 

Billion (Midsize) 

Less than $1 Billion 

(Smallest) 

5.2 Provision of Auxiliary Products by MSA 

Concentration of Branches

For some auxiliary products, such as check cashing, money 

orders, and official checks, high-MSA banks were less 

likely to offer products to noncustomers, compared to lowMSA banks. One possible explanation for this may be 

that low-MSA banks are similar to rural community banks 

that are more likely to know members of their community 

and provide these auxiliary services to noncustomers. Both 

midsize and the smallest low-MSA banks were more likely 

to cash payroll checks and offer money orders and official 

checks than were high-MSA banks. For example, for 

midsize banks:

• Fifty-two percent of low-MSA banks cashed payroll 

checks for noncustomers, compared to 41 percent of 

high-MSA banks. 

• Thirty-two percent of low-MSA banks offered money 

orders to noncustomers, compared to 23 percent of 

high-MSA banks. 

5.3 Auxiliary Products Offered at ATMs or Kiosks

The survey findings show that few banks provided auxiliary products to either basic accountholders or 

noncustomers at ATMs or kiosks. Only 8 percent of banks 

offered payroll check cashing at an ATM or kiosk, and 

only 5 percent of banks offered official checks or money 

orders in this manner. A similarly small proportion of 

banks offered noncustomers payroll check cashing, money 

orders, or official checks at an ATM or kiosk. 

5.4 Network-Branded Reloadable Prepaid Cards

Network branded reloadable prepaid cards are cards 

branded with a payment network logo (i.e., Visa, 

MasterCard, Discover, and American Express) that generally can be used at any merchant or ATM that accepts 

cards issued on the payment network. These card accounts 

are not linked to a deposit account. Banks also may issue 

these cards on behalf of third-party businesses that offer 

prepaid cards to customers. 

A small proportion of banks offered network-branded 

prepaid cards to customers or noncustomers. Among banks 

that responded, 23 percent offered network-branded 

reloadable prepaid cards to basic accountholders, while 14 

percent offered prepaid cards to noncustomers. Thirty-two 

percent of the largest banks, 19 percent of midsize banks, 

and 24 percent of the smallest banks offer customers this 

kind of prepaid card. Large banks were somewhat more 

likely than midsize or the smallest banks to offer these 

cards to noncustomers (25 percent for the largest banks 

versus 11 percent for midsize banks, and 15 percent for the 

smallest banks). Few banks issued network-branded 

prepaid cards on behalf of a third-party business (7 

percent). Twenty percent of the largest banks, 9 percent 

of midsize banks, and 7 percent of the smallest banks 

issued cards for that purpose. 

 5.5 Nontraditional Forms of Identification 

Accepted for Check Cashing

Among banks that cash checks for non-customers (39 

percent), 54 percent accepted foreign passports and 39 

percent accepted other foreign ID documents. A sizable 

majority of the largest banks accepted foreign passports or 

other foreign ID documents when cashing checks for 

noncustomers, nearly three-fourths of midsize banks and 

more than one-half of the smallest institutions also did so. 

Among banks that cash checks for non-customers, all of 

the largest banks, 66 percent of midsize banks, and 52 

percent of the smallest banks accepted foreign passports. 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

A smaller percentage of all banks accepted other foreign 

ID documents from noncustomers. Among banks that 

cashed checks for noncustomers, 83 percent of the largest 

banks, 53 percent of midsize banks, and 38 percent of the 

smallest banks accepted other types of foreign ID 

documents. 

5.6 Unsecured Personal Loans

The survey included a number of questions regarding 

unsecured personal loans and bank policies related to such 

loans. Specifically, it asked about the minimum dollar 

amount of the smallest unsecured, personal loan available 

to customers. The survey also asked whether the repayment period is at least 90 days; whether the annual 

percentage rate (APR) is 36 percent or less, including 

upfront fees and interest; and if the underwriting process is 

streamlined such that the loan decision can be made 

within 24 hours. 

Among all banks, 88 percent offered unsecured personal 

loans and 12 percent reported that they did not offer such 

loans. Among banks that offered unsecured personal loans, 

43 percent did not have a minimum loan amount and 53 

percent had a minimum loan amount of $2,500 or less but 

greater than zero. None of the largest banks reported 

making unsecured personal loans with no minimum loan 

amount requirement, while 27 percent of midsize banks 

and 45 percent of the smallest banks that offered unsecured loans did not require a minimum loan amount. 

Figure 5.6: Minimum Loan Amount of Unsecured 

Personal Loans by Asset Size (Percent) 

43 

53 

4 

14 

0 

70 

30 

20 

27 

63 

9 

18 

45 

52 

3 

14 

0 

10 

20 

30 

40 

50 

60 

70 

80 

No Minimum $1 to $2,500 More than $2,500 Does not make 

unsecured loans 

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

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

A large majority (82 percent) offered unsecured personal 

loans with no minimum or a minimum loan amount of 

$2,500 or less (“small dollar loans”). Among all banks, 83 

percent of the smallest banks, 74 percent of midsize banks, 

and 56 percent of the largest banks offered small dollar 

loans. 

Figure 5.7: Small Dollar Lending by Asset Size (Percent) 

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

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

82 

56 

74 

83 

0 

10 

20 

30 

40 

50 

60 

70 

80 

90 

Small Dollar Loans of $2,500 or Less 

Percentage of Banks 

Among banks that offered small dollar loans, a large 

majority offered loans with a repayment period of 90 days 

or more, an annual APR of 36 percent or less, and streamlined underwriting to make a loan decision within 24 

hours. Eighty-one percent of all banks with small dollar 

loans indicated that the repayment period on small, unsecured loans was 90 days or more. Eighty-six percent of the 

largest banks, 91 percent of midsize banks, and 81 percent 

of the smallest banks said they offered a repayment period 

of at least 90 days when they offered small dollar loans. 

The APR (including upfront fees) was reported to be at or 

below 36 percent at 89 percent of banks that offered unsecured personal loans. This was fairly similar across banks 

with different asset sizes. In addition, most banks could 

make a loan decision for small, unsecured loans in less 

than 24 hours. This was the case at 92 percent of the 

smallest banks, 82 percent of midsize banks, and 79 

percent of the largest banks with such a product. 

Figure 5.8: Features of Small Dollar Loans 

by Asset Size (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. Percentage of Banks 

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

81 89 92 86 93 

79 

91 96 

81 82 88 92 

0 

20 

40 

60 

80 

100 

120 

Repayment Period 

90+ Days 

APR of 36 Percent 

or Less 

Streamlined Application Process 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

VI. Financial Education and 

Outreach

Free counseling was the most frequently chosen and highly 

rated financial education and outreach activity by banks, and 

K-12 schools were the most commonly identified locations for 

conducting financial education and outreach activities. Almost 

one-third of all banks participated in all four financial education and outreach activities included in the survey. 

6.1 Types of Financial Education and Outreach 

The survey asked about the following types of financial 

education and outreach activities: teaching basic financial 

education topics, funding community partners, providing 

technical expertise, and offering free counseling. 

Free counseling was reported as the most frequently cited 

and highly rated financial education and outreach activity 

targeted to the needs of 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. By asset 

size, 96 percent of the largest banks said that they offered 

this type of education and 83 percent of these institutions 

rated its effectiveness as very effective or effective. 

Findings are similar for midsize and smaller banks, 

although the proportions were somewhat lower. 

Almost one-third of all banks (30 percent) participated in 

all four financial education and outreach activities 

included in the survey. Eighty-four percent of the largest 

banks, 61 percent of midsize banks, and 27 percent of the 

smallest banks participated in all four activities. 

6.2 Locations for Financial Education and 

Outreach 

The survey asked banks that participated in financial 

education and outreach activities about the locations 

where these activities took place, including public fairs 

and gatherings, workplaces, K-12 schools, government 

sites, bank branches, vocational schools and colleges, military installations, and nonprofit and community 

organization sites. 

K-12 schools were the most common locations cited by 

banks (74 percent) for conducting financial education and 

outreach activities. Ninety-two percent of the largest 

banks, 87 percent of midsize banks, and 73 percent of the 

smallest banks engaged in financial education at K-12 

schools. Seventy-seven percent of the largest institutions 

rated this location as very effective or effective, compared 

to 63 percent of midsize banks and 56 percent of the 

smallest banks. 

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

Figure 6.1: Financial Education and Outreach 

by Asset Size (Percent)

48 51 

56 

81 

88 

96 96 96 

83 83 84 84 

45 48 

53 

80 

0 

20 

40 

60 

80 

100 

120 

Teach Basic Financial 

Education Topics 

Funding to 

Community Partners 

Provide Technical 

Expertise 

Free Counseling 

Percentage of Banks 

All Banks Greater than $38 Billion (Largest) 

$1 Billion to Less than $38 Billion (Midsize) Less than $1 Billion (Smallest) 

6.3 Financial Education and Outreach by Branch 

Location

High-LMI banks (with branches concentrated in LMI 

neighborhoods) were somewhat more likely to engage in 

numerous financial education and outreach activities than 

were low-LMI banks, although in several cases the differences appear to be relatively small.15 As an example, 

almost 48 percent of high-LMI banks offered financial 

education and outreach at nonprofit, faith-based, or 

community organization sites, while 38 percent of lowLMI banks used these sites. 

High-MSA banks were modestly more likely to offer 

financial education and outreach at bank branches, workplaces, and nonprofit, faith-based, or other community 

organization sites than were low-MSA banks. Among 

high-MSA banks, 58 percent offered financial education 

and outreach at bank branches, while 48 percent of lowMSA banks provided these activities in bank branches. 

15 In all locations except workplaces, the difference in the proportion of 

banks conducting financial education and outreach between high- and 

low-MSA banks is significantly different. However, significant differences 

do not exist for K-12 school sites for high- and low-LMI banks. 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

frequently by midsize banks), and payday lenders (cited 

most frequently by the smallest banks).17

Thirty-five percent of banks reported that the regulatory 

environment was a major obstacle and an additional 30 

percent cited it as a minor obstacle. Among these respondents, between 35 and 40 percent reported that customer 

ID (40 percent), BSA/anti-money laundering requirements (34 percent) and fair lending/compliance risks (35 

percent) were major obstacles in offering financial products and services to underserved consumers. In contrast, a 

relatively smaller proportion of banks (close to 20 

percent) stated that third-party relationship risk was a 

major obstacle. 

7.1 Bank Business Challenges 

Bank business challenges include bank profitability, 

potential fraud issues, difficulties with underwriting, and 

competition from nonbank sources. 

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 bank business challenges were obstacles.

Figure 7.1: 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

Profitability was reported as a major obstacle in offering 

financial products and services to unbanked and underbanked consumers by 24 percent of banks, including 24 

percent of the smallest banks, 27 percent of midsize banks, 

and 46 percent of the largest banks. Fraud was viewed as a 

major obstacle by 32 percent of banks, including 40 

percent of the largest banks, around one-third of midsize 

(35 percent), and 32 percent of small banks. Roughly 16 

percent of all banks, including one in four of the largest or 

midsize banks and 15 percent of the smallest banks 

17 The survey asked questions about sources of nonbank competition to 

those respondents that said that nonbank competition was either a 

“major” or “minor” obstacle. The same methodology was used to identify 

types of regulatory challenges as obstacles. In this case, respondents 

were asked if the regulatory environment was a “major” or “minor” 

obstacle, and if so, the respondent was asked about types of regulatory 

challenges. 

VII.Potential Challenges 

to Offering Financial 

Products and Services

Banks were more likely to view fraud, underwriting, profitability, regulatory environment, and consumers’ lack of 

understanding about financial products and services as major 

obstacles and less likely to identify product development, product marketing, nonbank competition, lack of customer 

demand, or lack of familiarity with the banking needs of 

unbanked and underbanked consumers as major obstacles. 

When asked about specific potential regulatory concerns, a 

sizable proportion of institutions stated that customer ID 

requirements, Bank Secrecy Act (BSA)/anti-money laundering 

requirements, and fair lending/compliance risk were major 

obstacles in offering financial products and services to underserved consumers, while a relatively smaller proportion of 

banks viewed third-party relationship risk as an obstacle.16

Banks were asked about bank business, product-related, 

and regulatory challenges as obstacles to reaching 

unbanked and underbanked consumers. In general, banks 

were more likely to view fraud, underwriting, profitability, 

regulatory environment, and consumers’ lack of understanding about financial products and services as major 

obstacles in meeting the needs of underserved consumers. 

For example, about one-third of banks reported that fraud 

and the regulatory environment were major obstacles. By 

comparison, banks were less likely to view product development, product marketing, nonbank competition, lack of 

customer demand, or lack of familiarity with the banking 

needs of unbanked and underbanked consumers as major 

obstacles. As an example, less than 6 percent of all banks 

said that lack of familiarity with the banking needs of 

underserved consumers was a major obstacle. 

For banks that considered nonbank competition a major 

or minor obstacle, the most frequently cited sources of 

nonbank competition were: retail businesses offering 

general purpose reloadable prepaid cards (cited most 

frequently by the largest banks), check cashers (cited most 

16 FDIC Financial Institution Letter FIL-44-2008 defines third-party risk as 

including all entities that have entered into a business relationship with 

the financial institution, whether the third party is a bank or a nonbank, 

affiliated or not affiliated, regulated or unregulated, or domestic or foreign. 

The use of third parties in no way diminishes the institution’s responsibility to ensure that the third-party activity is conducted in a safe and sound 

manner and in compliance with applicable laws, regulations, and internal 

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

said consumers’ lack of understanding was a major 

obstacle. 

For banks of varying size, a very small proportion stated 

that lack of familiarity with the financial or banking needs 

of unbanked and underbanked consumers was a major 

obstacle in offering financial products and services. In 

particular, 4 percent of the largest banks, 7 percent of 

midsize banks, and 6 percent of the smallest banks said 

that lack of familiarity was a major obstacle in meeting 

the financial needs of these consumers. 

Lack of customer demand was a major obstacle to offering 

financial products and services to unbanked and underbanked consumers among a relatively low proportion of 

banks, with 8 percent of the largest banks, 14 percent of 

midsize banks, and 18 percent of the smallest banks 

reporting this challenge as a major obstacle. Close to one 

out of every five banks reported that effectively marketing 

products to unbanked and underbanked consumers was a 

major obstacle to offering financial services to these 

consumer segments, including 20 percent of the largest 

banks, 24 percent of midsize banks, and 19 percent of the 

smallest banks. 

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 challenges were obstacles.

Figure 7.3: Product-Related Challenges 

as Obstacles (Percent) 

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 

reported that nonbank competition was a major obstacle. 

Twenty-eight percent of banks reported that underwriting 

was a major obstacle, with results fairly consistent across 

large, midsize and small banks. 

Among banks that considered nonbank competition a 

major or minor obstacle, the source of competition varied 

by bank size. Among the largest banks, the most 

frequently cited source of nonbank competition was retail 

business offerings of network branded reloadable prepaid 

cards. Midsize banks reported check cashers and the smallest banks reported payday lenders as their most frequent 

source of nonbank competition. 

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 challenges were obstacles.

Figure 7.2: Types of Nonbank Competition 

as an Obstacle by Asset Size (Percent) 

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

types of nonbank competition as an obstacle.

14 

12 

17 

14 

7 

6 

17 

7 

10 

14 

33 

10 

4 

2 

0 

4 

35 

20 

6 

34 

30 

45 

28 

31 

0 5 10 15 20 25 30 35 40 45 50 

Less than $1 

Billion (Smallest) 

$1 Billion to Less than 

$38 Billion (Midsize) 

Greater than 

$38 Billion (Largest) 

All Banks 

Percentage of Banks 

Check Cashers Payday Lenders Money Order Providers 

Retail Prepaid Cards Other Don’t Know 

7.2 Product-Related Challenges 

Product-related challenges include product development, 

lack of consumer understanding about financial products 

and services, lack of familiarity with the financial needs of 

the underserved, lack of customer demand, and product 

marketing. 

Regardless of a bank’s size, a relatively small proportion of 

banks (12 percent) reported that product development 

was a major obstacle to offering financial products and 

services that meet the needs of unbanked and underbanked consumers. Eight percent of the largest banks, 15 

percent of midsize banks, and 12 percent of the smallest 

banks said that product development was a major obstacle. 

In addition, a reasonably large proportion of banks (31 

percent) stated that consumers’ lack of understanding 

about financial products and services was a major obstacle 

in meeting the needs of underserved consumers. Forty 

percent of the largest banks and roughly one-third of 

midsize (35 percent) and the smallest (31 percent) banks 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

midsize (33 percent) or the smallest banks (36 percent). 

Six percent of the largest banks, 15 percent of midsize 

banks, and 20 percent of the smallest banks reported 

third-party risk as a major obstacle in offering financial 

services to unbanked and underbanked consumers. 

7.3 Regulatory Challenges

Banks were asked whether the overall regulatory environment was an obstacle in offering financial products and 

services to unbanked and underbanked consumers. 

Respondents were also asked about specific regulatory 

topics, including customer ID, Bank Secrecy Act (BSA)/

anti-money laundering requirements, fair lending/compliance, and third-party relationship risk. 

The regulatory environment was cited as a major obstacle 

by roughly one-third of institutions. Specifically, 33 

percent of the largest banks, almost 32 percent of midsize 

banks, and close to 35 percent of the smallest banks 

reported that the regulatory environment was a major 

obstacle. Banks reporting that the regulatory environment 

was either a major or minor obstacle were further asked 

about whether customer ID requirements, Bank Secrecy 

Act (BSA)/anti-money laundering requirements, and fair 

lending/compliance risks were major obstacles in offering 

financial products and services to unbanked and underbanked consumers. The survey findings show that a 

reasonably large proportion of banks reported that 

customer ID requirements (40 percent), Bank Secrecy Act 

(BSA)/anti-money laundering requirements (34 percent), 

and fair lending/compliance risks (35 percent) were major 

obstacles in offering financial products and services to 

underserved consumers. 

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.

Figure 7.4: Regulatory Challenges as Obstacles (Percent) 

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 

Major Obstacle Minor Obstacle Not an Obstacle 

By asset size, customer ID concerns were reported as a 

major obstacle by around 40 percent of the smallest and 

midsize banks and 29 percent of the largest banks. BSA/

anti-money laundering was described as a major obstacle 

by 18 percent of the largest banks, 35 percent of midsize 

banks, and 34 percent of the smallest institutions. Fair 

lending/compliance was said to be a major obstacle by 24 

percent of the largest banks, and roughly one-third of 
2011 FDIC Survey of Banks’ Efforts to Serve the Unbanked an Uderbanked  •  

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 both 

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 recently obtained credit from payday 

lenders and almost 18 percent that used pawn shops did so 

primarily because they thought that banks did not offer 

small-dollar loans. 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 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. Close to 

one-half of all banks promoted both checking and savings 

accounts through partnerships with community organizations such as faith/community-based organizations, 

volunteer income tax assistance (VITA) sites, and 

schools. Even so, close to 51 percent of all institutions do 

not use partnerships. As such, a relatively large proportion 

of banks could benefit from expanding collaborative 

efforts to promote access to mainstream deposit accounts. 

5. Assess Whether Expanded Retail Strategies Can 

Improve Relationships with Unbanked and Underbanked Consumers

Regardless of a bank’s size, 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. 

VIII.Opportunities for Banks

Findings from the Bank Survey provide valuable insights 

into the efforts financial institutions have undertaken and 

the challenges they have encountered in expanding financial services to underserved consumers. This section 

discusses opportunities that institutions could explore to 

expand access to mainstream financial services and help 

meet the needs of unbanked or underbanked consumers. 

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, 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 requirements to avoid a fee 

were $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 card-based 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. Offering Additional Transaction Services to 

Underserved Households

Consumers’ use of nonbank financial services providers to 

meet their needs points to market opportunities for insured 

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

Conclusion

The findings in this report provide valuable information 

to financial institutions and other stakeholders interested 

in expanding financial products and services to unbanked 

and underbanked consumers. Based on responses to this 

2011 Bank Survey, five opportunities are highlighted that 

banks should consider taking advantage of to broaden 

access to mainstream financial services to the underserved: 

(1) expand offerings of basic, low-cost checking and 

savings deposit accounts, (2) offer additional transaction 

services to underserved households, (3) enhance smalldollar loan product marketing, (4) utilize partnerships 

with community organizations to promote checking and 

savings account ownership, and (5) assess whether 

expanded retail strategies improve relationships with 

unbanked and underbanked consumers.