Comments to FDIC re: Household Survey

Dear Ms. Cabeza,

The American Bankers Association (ABA) appreciates the opportunity to provide comments to theFederal Deposit Insurance Corporation’s (FDIC) survey collection instrument for its sixth National Survey ofUnbanked and Underbanked Households (Household Survey) scheduled to be conducted in partnershipwith the U.S. Census Bureau as a supplement to its June 2019 Current Population Survey. The HouseholdSurvey seeks to measure and track economic inclusion among U.S. households, to identify factors thatinhibit the participation of these households in the mainstream banking system, and to identifyopportunities to expand the use of banking services among underserved consumers. ABA supports thisimportant inquiry and offers the following comments to the Household Survey.

Starting with Question B30, the Household Survey asks about the participants’ experiences with bankaccounts, including “checking, savings, and prepaid cards from a bank.” We agree that prepaid cardsshould be classified as “bank accounts,” as functionally, prepaid accounts vary little from checkingaccounts. Both products provide similar deposit options and broad access to deposits through debit cardsand electronic banking features (online and mobile). In addition, while many prepaid accounts do not offercheck-writing services, some do, just as some checking accounts, such as the FDIC’s Model Safe Account,”do not. If the purpose is to measure people’s use of basic banking services, prepaid cards should beincluded, as they serve that purpose.

Question BR15 asks how often participants with an account have spoken with a teller or otheremployee in person at a bank branch in the last 12 months. We recommend adding two short questions to explore the reasons people use branches. The answers to these questions would be helpful to determine the primary reasons customers use and value branches and to identify opportunities to expand bankingservice options, especially for those who lack convenient access to branches.

Following question BR15, we recommend the FDIC add:

Q. If you have spoken with a teller or other employee in person at a bank branch in the past 12months, what were the reasons for doing so? Check all that apply.

• Cash a check
• Deposit a check
• Withdraw cash
• Obtain a money order or cashiers' check
• Wire funds
• Use a notary
• Meet face-to- face with someone to sort out a problem or ask questions
• Learn about a new or existing product or service
• Ask for financial advice and learn about bank's advisory services (e.g. brokerage accounts,insurance)
• Use the ATM3
• Inquire about loans (including credit card)
• Apply for a loan (including credit card)
• Access a safe deposit box
• Other -- please describe

Q. What were your primary reasons for speaking with a teller or other employee in person at a bankbranch in the past 12 months? Check four (or other number).

ABA appreciates the opportunity to comment on this important matter and is happy to provideadditional information. If you have any questions about these comments or would like to discuss anymatter further, please contact Nessa Feddis at 202 663-5433 or [email protected].

Sincerely,

Nessa E. Feddis
Senior Vice President & Deputy Chief Counsel for
Consumer Protection and Payments