Q: § __.24(d)(3) – 1: How do examiners evaluate alternative systems for delivering retail banking services?
A: There are a number of alternative systems used by financial institutions to deliver retail banking services to customers. Non-branch delivery systems, such as ATMs, online and mobile banking, and other means by which institutions provide services to their customers evolve over time. No matter the means of delivery, examiners evaluate the extent to which the alternative delivery systems are available and effective in providing financial services to low- and moderate-income geographies and individuals. For example, a system may be determined to be effective based on the accessibility of the system to low- and moderate-income geographies and individuals. To determine whether a financial institution’s alternative delivery system is an available and effective means of delivering retail banking services in low- and moderate-income geographies and to low- and moderate-income individuals, examiners may consider a variety of factors, including
• the ease of access, whether physical or virtual;
• the cost to consumers, as compared with the institution’s other delivery systems;
• the range of services delivered;
• the ease of use;
• the rate of adoption and use; and
• the reliability of the system.
Examiners will consider any information an institution maintains and provides to examiners demonstrating that the institution’s alternative delivery systems are available to, and used by, low- or moderate-income individuals, such as data on customer usage or transactions.
This Interagency Q&A, and others, was released in July 2016.
The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately. They may be found here: http://www.ffiec.gov/cra/qnadoc.htm