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#1597530 - 08/29/11 12:57 PM Does "No Free Checking" effect Service Credit Test
JUST CALL ME CRA Offline
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I am just wondering if anyone works for a bank that does not have a free checking product that has gone through an exam. How much does it impact the service test rating.
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#1602846 - 09/13/11 03:10 PM Re: Does "No Free Checking" effect Service Credit Test JUST CALL ME CRA
JUST CALL ME CRA Offline
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I would love to get a regulator's thoughts on this.
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#1603149 - 09/13/11 08:33 PM Re: Does "No Free Checking" effect Service Credit Test JUST CALL ME CRA
Pale Rider Offline
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The majority of banks do not offer free checking. More than 95% of those are rated O or S. My bank does not have free checking and we have 5 charters from 3 different federal agencies, all are rated O.
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#1603532 - 09/14/11 05:04 PM Re: Does "No Free Checking" effect Service Credit Test Pale Rider
JUST CALL ME CRA Offline
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Joined: Aug 2002
Posts: 133
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That's good to know. I guess it's just what is common in our market. Thank you for your response.
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#1603552 - 09/14/11 05:27 PM Re: Does "No Free Checking" effect Service Credit Test JUST CALL ME CRA
Pale Rider Offline
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under the Lone Star
You should be good if your branches serve the AA equally, your products and services are accessible to all geographies and income groups, and you haven't closed any branches, especially in LMI areas, without a sound written justification for doing so.

The service test is only 25% of the overall grade.
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Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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#1603555 - 09/14/11 05:36 PM Re: Does "No Free Checking" effect Service Credit Test Pale Rider
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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For a large bank it is 25% of the grade. For a small bank or ISB where everything gets lumped, do a thorough analysis of your CD efforts overall and make the case that you adequately serve your community (hopefully you can!).

Highlight any low cost checking you offer if you eliminate no cost (and many banks do offer no cost..including some big banks still offering it).

Some states have requirements for low cost low opening balance checking (such as NJ). Check your state laws.

There is no one specific requirement...it is a balance.
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