Turn the tables on your bank.
Similar to how a bank can pull a report that
has information about your past, you can easily
pull a report that has information about your
bank's past. Each branch of each bank is
required to provide to you information about how
well that branch meets the credit needs of your
community. This requirement is part of the
Community Reinvestment Act. (Note - credit
unions are execpt from CRA requirements.)
We are helping to coordinate a CRA hit squad
which focuses on one bank at a time in hopes
of convincing the banks to reconsider their
policies regarding ChexSystems. We've started the
CRA Hit Squad Message Board
to help coordinate which banks to hit and when, and
know which branch locations have already been hit.
The message board allows anonymous posts, so
everyone should feel comfortable participating.
Here are step-by-step instructions on what to do:
Plan an opportune time. If the bank is really
busy, they will notice the interruption even more.
4:30 pm on a Friday always seems to be a good
Bring a microcassette tape recorder with you.
Should the bank be less than willing to cooperate.
a recorder will help convince them that you are
familiar with the regulations and that your
taped conversation would be used should you need
to report them to the
Print out some supporting documents which you
may need to help your bank remember what they
are required to do.
Print out the
Federal Reserve's CRA web page (specifically,
page five) which states clearly what your bank
must provide. Also, consider printing out our
CRA Hit Squad explanation page
which you can present to the banker
after you are done to help inform them that their
ChexSystems policy needs to be reconsidered.
When you visit the bank, go to the information
desk or, preferably, walk up to any teller
and ask to see the bank's CRA (Community
Reinvestment Act) Files. The bank is required
to have this available for you to inspect at
no charge, any time the bank is open.
They generally will already have a folder ready
This document should be updated each year so if
the copy you are shown is an evaluation dated
more than 12 months ago, you will want to ask
them for the most recent copy.
(They probably will need to contact their CRA
coordinator to get an updated copy delivered
This folder probably will not have any location-
specific information. That information is
normally just kept by the CRA coordinator at
the bank's headquarters. This location-specific
information will include:
- a map of the bank's assessment area showing its
boundaries and identifying the various geographic
areas within it.
- all written comments from the public
(and the bank's response to each) about how the
bank is helping meet community credit needs.
What you want to do is to ask for
"the information in the public file relating to
that branch's assessment area".
To meet that request, generally, the branch
manager ends up contacting the CRA coordinator
at the bank's headquarters, who then needs to make
copies of a bunch of documents and courier
them to the bank branch where your request was
made. They have five [business] days to make
these documents available to you for you to
inspect. The bank cannot refuse to do this for
you without breaking federal CRA law.
(Your banker may not know what you are asking for,
as they don't receive this type of request all that
often. But be persistent, as federal law mandates
that these files be made available to you. If the
bank says you need to visit a different branch,
show them page 5 of the CRA document you printed out.
It is up to them to get the documents sent to your
branch location. If the bank says there is a charge,
let them know that you can only be charged if you are
asking for a copy to take home. If you are going to
simply inspect their copy on-premises at the bank,
they cannot charge you a dime. Here are some other
documents that you might want to direct them to:
A Banker's Quick Reference Guide to CRA
A Guide to Small Bank Public Performance
Evaluations Under the CRA,
both of which are made available by the
Dallas branch of the Federal Reserve.)
Go back to the
CRA Hit Squad Message Board
and post which branch location you visited.
The efforts of the CRA Hit Squad will be more effective
when many different branch locations of the same
bank are visited within a short time. The impact
is minimal when a single location is hit twice as
the file obtained during the first request can be
used to satisfy subsequent requests. So please make
sure to provide the follow-through posting.
Write a letter to your bank and ask that the
letter be included in the bank's CRA public file.
The topic of your letter might be something
along the lines of how you believe the bank is
not serving the credit needs of the community
because of their ChexSystems policy.
Since the banks won't listen to us normally, we
use this wonderful tool known as the CRA files
to help get our message across. When we
communicate and coordinate, we will make a
On a related not, see the
Hunt For Wells Fargo Bank's 'Do No Call' Policy
which documents a similar effort.