I suppose I might add that offering a product to assist CRA is a good thing, unless the bank doesn't want anyone to use it. Then it should be discontinued and the bank needs to know CRA won't be an issue because the problems are resolved, there are no unbanked, etc. If there have been discussions with regulators or community groups about providing these accounts, I'd seriously look at the risk. If its a cost issue, attack it another way. CRA doesn't say you have to lose money.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell