If a bank wanted to create a product for those persons who would not meet the requirements for full service free checking (which includes debit card use, and overdraft coverage for those that qualify) - what should the institution look for in regards to meeting reg requirements, not being discriminatory and wording the offering in a fair and consistent manner?

The new account would be for individuals who have unpaid debt on their cheksystems reports, etc. A basic account for them that perhaps would require direct deposit as a criteria of opening and maintaining the account. Does anyone have a recommendation or any thoughts on this matter?

Thank you

There are several banks in my area, including my own, who have this type of account. It's geared to the individual who has had a checking account closed by a financial institution because they did not know how to reconcile and maintain an account. The program includes proof from financial institution that submitted a report to ChexSystems indicating settlement of loss; take a course on how to maintain a checking account with a non-profit consumer credit counseling org; a monthly fee disclosure for the account; criteria which could close the account (such as writing NSF checks; criteria (no nsf's within a year)by which the the account can be converted to a regular account with no fees. We don't require direct deposit, but there should be no reason why you couldn't as long as you disclose this requirement up front. Disclosures up front prevent the perception of discrimination.