Banks generally cannot profitably make loans to people with low credit scores in the current regulatory environment. In May 2016, American Banker reported that at least three large banks were planning to use the 5 percent payment option that the CFPB proposed in its 2015 framework to offer such customers small loans repayable in affordable installments at prices roughly six times lower than average payday loans, such as a $400, three-month loan for a $60 fee.6 Most Americans would like to see banks begin offering these loans.

Seventy percent of survey respondents said they would have a more favorable view of a bank if it offered a $400, three-month loan for a $60 fee (as some banks are planning to do).7 Banks report that they would need to use the 5 percent payment option in order to make these loans available.


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By a margin of almost 5 to 1, respondents said it would be a good thing if banks began offering small loans at prices six times lower than those of payday lenders, even if the rates would be higher than those for credit cards. All payday loan borrowers have a checking account because it is a loan requirement, so if these loans became available, they would be likely to replace a large share of high-cost loans.

Banks are required by law to have a customer identification program that includes performing due diligence (also called Know Your Customer) in creating new accounts by collecting certain information from the applicant. An account is a formal banking relationship established to provide or engage in services, dealings, or other financial transactions including a deposit account, a transaction or asset account, a credit account, or other extension of credit. The term includes a relationship established to provide a safety deposit box or other safekeeping services, and cash management, custodian, and trust services.

Each bank's customer identification program must include procedures for verifying the identity of each customer. At a minimum, when opening a new account, a bank must obtain the following information as part of its program:

The bank must then verify the accuracy of the information the applicant provided by reviewing documents, such as a driver's license or passport. It can also verify the information by other means, such as comparing it with information from a credit reporting agency or by checking the applicant's references with other financial institutions.

Please note: The terms "bank" and "banks" used in these answers generally refer to national banks, federal savings associations, and federal branches or agencies of foreign banking organizations that are regulated by the Office of the Comptroller of the Currency (OCC). Find out if the OCC regulates your bank. Information provided on HelpWithMyBank.gov should not be construed as legal advice or a legal opinion of the OCC.

To reinvent their key customer journeys, banks should first understand and assess the experiences of current customers and then develop a comprehensive baseline of their most significant journeys. Full-service corporate banks typically find that they have around 30 such journeys.

We note that banks must involve their second- and third-line functions, especially risk, as they shape these new processes. These functions will play a critical role in introducing important innovations, such as advanced risk analytics, for example, which will change the way credit risk management is conducted. Their approval will be essential to successful implementation.

Make high-tech talent a priority. Because banks compete with technology companies and others for scarce talent, such as data scientists and automation engineers, they must work to attract and retain digitally savvy employees. To succeed, banks must fight against the traditional mindset that views IT as a low-profile, back-office cost generator, rather than the critical element in generating new business that it is today. Note that essential digital talent, especially in IT, should not be outsourced. This is for two reasons: banks need continuity and, most important, IT staff are now a core part of the business team, generating tangible value together with the front office.

Second, corporate banks should begin to transform the organizational setup to accommodate these new and agile ways of working, ultimately transforming from a straightforward, classic, line organization to one that is structured around the new customer journeys.


Verizon, AT&T and T-Mobile are asking customers to move their monthly bill payments from their credit cards to their bank accounts. WSJ personal-technology editor Shara Tibken joins host J.R. Whalen to discuss why the carriers want the change, the privacy concerns that have been raised about it and the financial trade-offs to consider before you make the switch.

J.R. Whalen: Here's Your Money Briefing for Tuesday, September 5th. I'm J.R. Whalen for The Wall Street Journal. If you're like a lot of people, you pay your monthly cell phone bill automatically through your credit card. Easy enough, and the rewards you get aren't bad either. But now phone carriers are asking customers to make a switch and pay their bill directly from their bank account.

Shara Tibken: So basically they're giving you a five or $10 discount per line per month, or if you were already getting that discount for setting up autopay, they're saying, "Hey, we're going to take that discount away if you don't switch to your bank account."

J.R. Whalen: So what questions should you ask before making the switch? We'll find out from our personal tech editor, Shara Tibken after the break.Mobile phone carriers are trying to get people to switch from paying their monthly bill through a credit card to directly from their bank account, but is that a good idea for you? I'm joined now by WSJ Personal Technology editor, Shara Tibken. So Shara, why are the carriers asking customers to switch over to paying their bill through a bank account or a debit card?

Shara Tibken: It's really about the credit card fees. They've been increasing over the past couple of years and we reported that they are going to be increasing a couple more times in the next nine months. So, these carriers do not want to pay those fees. So they're basically incentivizing us to start paying with our bank accounts. There are also a couple of other benefits for them. If you have autopay set up and you pay with your bank account, you're less likely to cancel. It's not actually difficult to change your payment method or it's not difficult to cancel, but it's that mental hurdle to get past. Also, with the discounts that they're giving us, that also makes you feel more loyal. People don't switch carriers very often, but we all still like being rewarded for that loyalty.

Shara Tibken: So basically, they're giving you a five or $10 discount per line per month, or if you were already getting that discount for setting up autopay, they're saying, "Hey, we're going to take that discount away if you don't switch to your bank account." They're really trying to push people to get away from using their credit cards.

Shara Tibken: We're basically seeing those savings through the discounts. In a lot of cases, these discounts are actually more than what maybe the credit card fees would amount to. They're incentivizing us through these discounts because otherwise, there's not really a lot of incentive to pay with your bank account. There's a lot of perks that you get through paying with credit cards a lot of times. In order for them to get those savings and have this as a long-term savings for them, they're giving us the discounts. And the discounts aren't like you get a discount for a month, they're indefinitely, unless they change the terms in six months, who knows? But generally they're long-lasting discounts.

J.R. Whalen: In a lot of cases, the carriers have had info on the credit card that people have been using for payment, but now the carriers will have info on the bank account, which potentially touches a lot of areas of people's personal finances. Have privacy or security concerns been raised about that?

Shara Tibken: That was something I asked a lot of experts about. What they told me is Paying by ACH, which is your one financial institution talking to the other, they said it's really safe. I think a lot of us have paid that way to pay our energy bills or other utility bills that we have. In a lot of cases, these companies are working with these third-party such as Plaid or Trustly, and those companies, their entire business is linking your bank accounts with the carrier. So, what they do is auto-populate it. Your carrier doesn't see your bank login. That still is kept private. So, what these third-parties do is really just make that link. There's also an option with these companies where you can enter your bank accounts and the routing number. They don't see every payment that you've made or have other sensitive information about you, but you really need to be sure that you trust your carrier. e24fc04721

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