Interagency Q&A .24(d)(3) – 2: Are debit cards considered under the service test as an alternative delivery system?

Compliance > Regulation BB - CRA
Q:  § __.24(d)(3) – 2: Are debit cards considered under the service test as an alternative delivery system?
 
A:  By themselves, no.  However, if debit cards are a part of a larger combination of products, such as a comprehensive electronic banking service, that allows an institution to deliver needed services to low- and moderate-income areas and individuals in its community, the overall delivery system that includes the debit card feature would be considered an alternative delivery system.
 
 
 
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
 
 

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