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Converting Basic Financial Services Fees into Prosperity
An Untapped Opportunity for Consumers and Banks


Quick Summary

12 percent of California households lack a bank account and pay fees to cash checks and pay bills, adding up to $700 annually for the typical unbanked household.  The majority of these households appears to be qualified for bank accounts, but is either misinformed about the relative cost of banks or distrustful of them.

Converting Basic Financial Services Fees into Prosperity
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Contact

Nicolle Grayson, Tel: 202-540-6347

Report Project

Safe Banking Opportunities Project

Recommendation and Conclusion

We find that about 58 percent of households in the state are now being charged overdraft fees, credit card late payment fees, out-of-network ATM fees, or check-cashing fees. Across the United States, these fees add up to over $58 billion each year. And contrary to common perception, the bulk of households paying to use these basic banking services is middle-class, relatively well-educated, and technologically savvy consumers. Usage of most of these fees tends to be highly episodic for most households, and not something that occurs regularly and systematically. The lone exception is the check-cashing market, which is dominated by lower-income households with low levels of educational attainment and that rely heavily on expensive non-bank fee-based services.

In response, we review a new role for public leaders to serve as intermediaries in the market that can connect households to existing lower-priced alternatives. Oftentimes, there are financial institutions that sell lower-cost alternatives, but consumers sometimes have difficulty finding these products for a number of reasons. Using a model developed by the city of San Francisco, cities and states around the country can create enormous savings for their constituents by helping them find lower-priced alternatives to the products and services on which they currently rely. Of particular importance is the unbanked market, which largely relies on overpriced products and services. There does seem to be a minority of unbanked households that cannot be served by traditional bank accounts, requiring non-traditional services like prepaid products (although suitable prepaid products are extremely difficult to find in the market).69 The survey data suggest, however, that a large share of the non-banks serving this market operates on an economic model that is at a competitive disadvantage and, as a result, can be cannibalized by depository institutions.

Before we review this recommendation in greater detail, it is important to stress that we do not comment on the validity of these fees, as others have elsewhere, because we do not have data that speak to the margin generated by these fees and therefore cannot reliably assess the extent to which there are excesses. We also do not have data that adequately capture whether consumers are actively steered by financial institutions into product agreements with an increased likelihood of service charges. Without that information, it is impossible for us to assess the validity of these fees.

State and local governments can connect consumers to fee-based products and services that are already widely available at a lower cost than those that they currently use. For instance, we discuss in the Findings section that most banks offer customers a range of overdraft protection programs, from the very expensive fee-based model to the less expensive linked-account or revolving-account model. These less expensive linked-account programs can potentially save consumers billions of dollars because, as we reviewed earlier, the majority of households that overdraw their accounts have a savings account they could link to. Similarly, we have pointed to a large share of the unbanked population currently relying on expensive non-banks who would be better off switching to low-cost starter bank account products. For a number of reasons, households have trouble finding these lower-cost alternatives on their own. Some do not understand the fee structure of these products; some have trust and misperception barriers; some simply do not spend the time to shop around, or are easily steered toward more expensive product alternatives. Regardless of the specific reason, policymakers can illuminate the product market for consumers and connect them to lower-cost services. This approach short-circuits other, more uncertain, politically difficult policy options. It also takes advantage of products that are already in the market.

Read Full Section: Recommendation and Conclusion (PDF)

Table of Contents
 

Date added:
Dec 12, 2008
Contact:
Nicolle Grayson, Tel: 202-540-6347
Project:
Safe Banking Opportunities Project
References:
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References:

  1. Authors’ analysis of data from the FDIC Institution Directory’s Statistics on Depository Institutions. Please note, however, that this growth in noninterest income has also substituted for income once earned by financial institutions through other means. For instance, consumers now pay fees for foreign¬currency transactions at ATMs in addition to or instead of at a foreign-currency vendor, once the primary mechanism for accessing capital in a foreign country. Similarly, Visa and MasterCard once added a 1 percent charge to any foreign transaction but now charge consumers a flat fee, which has the effect of moving “sales income” into the “fee income” side of a bank’s ledger.
  2. Authors’ analysis of data from the U.S. Census Bureau, Current Population Survey, Annual Social and Economic Supplements.
  3. Estimate provided to The Pew Charitable Trusts by Moebs Services, Inc. For instance, Moebs estimates that consumers now pay $34 billion in overdraft fees every year. Note that a higher estimate published in a recent GAO report also includes enterprise overdrafts.
  4. Bankrate.com (August 2008)
  5. Please see, for instance: Appendix 3 in Matt Fellowes and Mia Mabanta, “Banking on Wealth: America’s New Retail Banking Infrastructure and Its Wealth-Building Potential” (Washington: Brookings Institution, 2008).
  6. For instance, for an analysis of how the checking account overdraft fee has evolved, please refer to: American Bankers Association Banking Journal, “Consumer Checking Account Challenge: Giving an old banking spud new profit appeal” (2004).
  7. General Accountability Office, “Bank Fees: Federal Banking Regulators Could Better Ensure That Consumers Have Required Disclosure Documents Prior to Opening Checking or Savings Accounts.” GAO¬08¬281 (Government Printing Office, 2008).
  8. Please see, for instance: Sumit Agarwal, John C. Driscoll, Xavier Gabaix, and David Laibson, “Learning in the Credit Card Market,” Working Paper No. 13822 (National Bureau of Economic Research, 2008); Barry Williams and Gulasekaran Rajaguru, “The trade¬off between bank non interest income and net interest margins,” Working Paper (Bond University School of Business, 2008); Nadia Massoud, Anthony Saunders and Barry Scholnick, 2007, “The Cost of Being Late: The Case of Credit Card Penalty Fees,” Chicago Meetings Paper (American Finance Association, 2007); Arnold S. Rosenberg, “Regulation of Unfair Bank Fees in the United States and the European Union: Current Trends and a Proposal for Reform.” In Evolving Legislation on Consumer Credit and Trade Practices, APS Occasional Papers 7 (2007) (Proceedings of 2006 Malta Conference of the International Association of Consumer Law on Consumer Protection Law in the European Union); Timothy Hannan and Ron Borzekowski, “Incompatibility and Investment in ATM Networks,” Review of Network Economics 6 (2007): 1-15; Sujit Chakravorti and William Emmons, “Who pays for credit cards?” The Journal of Consumer Affairs 37 (2) (2003): 208-230; Timothy H. Hannan, “Retail Fees of Depository Institutions, 1994-99” Federal Reserve Bulletin, January 2001; Christoslav E. Anguelov, Marianne
    A. Hilgert, and Jeanne M. Hogarth, “U.S. Consumers and Electronic Banking, 1995-2003” Federal Reserve Bulletin, Winter 2004; Joanna Stavins, “ATM fees: Does bank size matter?” New England Economic Review (Boston: Federal Reserve Bank of Boston, 2000); Joanna Stavins, “Checking accounts: What do banks offer and what do consumers value?” New England Economic Review (Boston: Federal Reserve Bank of Boston, 1999). Please see endnote 1 for examples of the substitution that has occurred in the market.
  9. For an example of the controversy surrounding these fees, please see: Center for Responsible Lending, “Overdraft Loans Trap Borrowers in Debt: Unfair bank practices artificially increase fees” (2008). Or see recent hearings on these issues, including: Overdraft Protection: Fair Practices for Consumers, Hearings before the Subcommittee on Financial Institutions and Consumer Credit of the House Committee on Financial Services, 110 Cong. 1 sess. (GPO, 2007); The Credit Cardholders’ Bill of Rights: Providing New Protections for Consumers, Hearings before the Subcommittee on Financial Institutions and Consumer Credit of the House Committee on Financial Services, 110 Cong. 2 sess. (GPO, 2008)
  10. Note, though, that having a lower income may also make a household more aware of its budget limitations than a higher-income household might be. We merely repeat this conjecture as an example of an opinion that has emerged in the context of little data.
  11. Again, we state this as an example of a conjecture that can emerge in the absence of data. While it is certainly true that debt-to-income ratios are high among middle-and higher-income households, too, multiple years of data from the Federal Reserve’s Survey of Consumer Finances make clear that this ratio is persistently higher among lower-income households.
  12. For some past insight into this question, please see: Jennifer Roth, “Walk-in Bill Payment: The Rational Option for the ‘Cash-Preferred’ Market” (Needham: Tower Group 2008); Center for Financial Services Innovation, “Underbanked Consumer Overview & Market Segments” (2008); and Fellowes and Mabanta, “Banking on Wealth: America’s New Retail Banking Infrastructure and Its Wealth¬Building Potential.”
  13. Bankrate.com (October 2008).
  14. Banks would have to open more accounts belonging to households in this group to achieve the same potential float as they would by opening accounts for households with higher incomes; also, it’s likely that fewer cross-selling opportunities exist within the former group. Large shares of unbanked households have low levels of education and speak Spanish, requiring higher levels of customer interaction, a primary cost driver in retail banking business models. There is also a large minority of unbanked clients with checkered account histories, indicating that there will be fewer qualified households returned from advertising investments in lower-and moderate-income markets compared to those made in higher-income markets. These facts make the basic lower-income market equation for bankers clear: lower relative benefits + higher relative costs = a less attractive business opportunity.
  15. We review in the Methodology section the full suite of fees that are now tied to basic banking services.
  16. Estimate provided to The Pew Charitable Trusts by Moebs Services, Inc.
  17. American Bankers Association Banking Journal, “Consumer Checking Account Challenge: Giving an old banking spud new profit appeal.”
  18. We want to be clear that we do not have usable data on the margins generated by these fees and therefore cannot reliably assess the extent to which there are excesses. For commentary along these lines, please see: Overdraft Protection: Fair Practices for Consumers, Hearings before the Subcommittee on Financial Institutions and Consumer Credit of the House Committee on Financial Services; and The Credit Cardholders’ Bill of Rights: Providing New Protections for Consumers, Hearings before the Subcommittee on Financial Institutions and Consumer Credit of the House Committee on Financial Services.
  19. Emerging Markets, www.emergingmarkets.us (October 2008).
  20. One question was open-ended, asking the respondents to name the two magazines that they most frequently read.
  21. The sample was constructed to draw equal sample sizes from each of the state’s income quartiles. For one assessment of how the landline population differs from the mobile phone population, please see: Michael W. Link, Michael P. Battaglia, Martin R. Frankel, Larry Osborn and Ali H. Mokdad, “Reaching the U.S. Cell Phone Generation: Comparison of Cell Phone Survey Results with an Ongoing Landline Telephone Survey,” Public Opinion Quarterly 71 (5) (2007): 814¬839.
  22. CSRS terminated 344 interviews with respondents who did not know or refused to provide their income information; these households are not included in the final 2,001 count.
  23. CfMC is a commonly used survey research software.
  24. Information about these fees was collected from a number of sources including a) the authors’ analysis of bank websites, b) Bankrate.com (August 2008), and c) BankingMyWay.com (August 2008).
  25. For instance, please see: GAO, “Bank Fees: Federal Banking Regulators Could Better Ensure That Consumers Have Required Disclosure Documents Prior to Opening Checking or Savings Accounts.”
  26. Authors’ analysis of the American Community Survey.
  27. Ibid.
  28. For a helpful primer of bank-related markets discussed in this section, please see: Barry Scholnick, Nadia Massoud, Anthony Saunders, Santiago Carbo-Valverde, and Francisco Rodríguez-Fernández, “The economics of credit cards, debit cards and ATMs: A survey and some new evidence,” Journal of Banking & Finance 32 (8) (2008): 1468¬1483. For a helpful primer on the non-bank related markets discussed in this section, please see: Rebecca M. Blank, “Public Policies to Alter the Use of Alternative Financial Services among Low-Income Households” (Washington: Brookings Institution, 2008).
  29. For an analysis of how the checking account overdraft fee has evolved, please refer to American Bankers Association Banking Journal, “Consumer Checking Account Challenge: Giving an old banking spud new profit appeal.” For the purpose of simplicity, we use the term “overdrafts” throughout this section to refer to both overdrafts and nonsufficient funds even though the two are technically different activities. However, the rates tied to both services, as well as the account balance threshold that triggers them, are nearly identical.
  30. For instance, an overdraft of $37 might lead to a loan of $50 or $100 from a financial institution.
  31. GAO, “Bank Fees: Federal Banking Regulators Could Better Ensure That Consumers Have Required Disclosure Documents Prior to Opening Checking or Savings Accounts.”
  32. The phrase “past year” or “previous 12 months” throughout the paper refers to the period between May 2007 and May 2008.
  33. Estimate provided to The Pew Charitable Trusts by Moebs Services, Inc.
  34. Consider, for instance, a hypothetical household that had a checking account balance of $50 and was enrolled in a fee-based overdraft program. If this household were to write in one sitting four checks each worth over $50 and collectively totaling $250, they would pay four overdraft fees but likely recall it as only one overdraft incidence.
  35. Our data indicate that this group of high frequency overdraft users accounts for about 4 percent of the overall checking account market, but around 30 percent of all overdrafts (and, again, the data cannot distinguish whether these self-reported instances of an overdraft account for one or more fees at a time, so the overall share of overdraft revenue generated by this small share of households may be quite a bit larger).
  36. Allowable check-holding periods are governed under the Expedited Check Funds Availability Act, with implementing language in Federal Reserve Regulation CC. For a readable interpretation of these regulations, please refer to the Office of the Comptroller of the Currency’s guide to funds-holding rules, available at www.helpwithmybank.gov/faqs/banking_funds _available.html#drop03 (October 2008)
  37. For a full list of allowances please refer to the Office of the Comptroller of the Currency resource, cited above.
  38. In particular, the data indicate that households that have their paychecks directly deposited stand a one-in-four chance of overdrawing their accounts, compared to about a one-in-five chance among households that deposit their paychecks themselves. Although funds are more swiftly made available for households that directly deposit, it’s possible that the automation of this process may result in households being comparably less aware of their balances, spurring a modestly higher propensity to overdraw their accounts.
  39. GAO, “Credit Cards: Increased Complexity in Rates and Fees Heightens Need for More Effective Disclosures to Customers.”
  40. GAO, “Credit Cards: Increased Complexity in Rates and Fees Heightens Need for More Effective Disclosures to Customers.”
  41. Federal Reserve Board, “Survey of Credit Card Plans,” updated on January 31, 2008. Full list of surveyed credit cards and more details on each are available here: ww.federalreserve.gov/Pubs/shop/survey.htm (August 2008)
  42. GAO, “Credit Cards: Increased Complexity in Rates and Fees Heightens Need for More Effective Disclosures to Customers.”
  43. Estimates based on data from CardWeb.com, Inc., which reports that the average U.S. household owns 6.3 bank credit cards. Please see: Kathleen Day and Caroline E. Meyer, “Credit Card Penalties, Fees Bury Debtors: Senate Nears Action on Bankruptcy Curbs,” Washington Post, March 6, 2005.
  44. It should be noted, however, that although nearly one in five households falls behind on its payment schedules, at least once a year, it’s unlikely that these households consistently pay their bills late throughout the year. Quarterly data from TransUnion indicate that, in the 15-year span between1992 and 2007, the credit card delinquency rate in California hovered between 1.1 percent and 2.7 percent. These data suggest that there is substantial churn in this market; households are slipping up once or twice in the span of year, but for the most part report that they pay off their balances according to schedule. This evidence of churn is supported by additional recent research that found paying a fee taught consumers to avoid paying future fees.
  45. Kathy Chu, “Facing losses on bad loans, banks boost credit card rates,” USA Today, February 8, 2008; R.K. Hammer Consulting Firm.
  46. For a recent assessment of the national credit card market, please see: Edward Castronova and Paul Hagstrom, “The demand for credit cards: Evidence from the survey of consumer finances,” Economic Inquiry 42 (2) (2004): 304-318.
  47. The sample included credit cards that were active between 1997 and 1999. Sumit Agarwal, Souphala Chomsisengphet, Chunlin Liu, and Nicholas Souleles, “Do Consumers Choose the Right Credit Contracts?” Working Paper 06¬11 (Federal Reserve Bank of Chicago, 2006).
  48. Nadia Massoud, Anthony Saunders, and Barry Scholnick, “Who Makes Credit Card Mistakes?”
  49. GAO, “Bank Fees: Federal Banking Regulators Could Better Ensure That Consumers Have Required Disclosure Documents Prior to Opening Checking or Savings Accounts.”
  50. Joanna Stavins, “Credit Card Borrowing, Delinquency, and Personal Bankruptcy,” New England Economic Review (Boston: Federal Reserve Bank of Boston, 2000).
  51. Laura Bruce, “2008 Checking Account Study,” Bankrate.com (November 2008).
  52. For other related work in this area, please see: Christopher R. Knittel and Victor Stango, “Incompatibility, Product Attributes and Consumer Welfare: Evidence from ATMs,” B.E. Journal of Economic Analysis and Policy: Advances in Economic Analysis and Policy 8 (1) (2008); Christopher R. Knittel and Victor Stango, “Strategic Incompatibility in ATM Markets.” NBER Working Paper No. 12604 (National Bureau of Economic Research, 2006); Elizabeth W. Croft and Barbara J. Spencer, “Fees and Surcharging in automatic teller machine networks: Non-bank ATM providers versus large banks.” NBER Working Paper No. 9883 (National Bureau of Economic Research, 2003).
  53. Please refer to the section that reviews the unbanked statistics for an explanation of this range.
  54. Greg McBride, “2007 Checking Account Pricing Study,” Bankrate.com (November 2008)
  55. For a recent assessment of the national market for debit cards, please see: Ron Borzekowski, Elizabeth K. Kiser, and Shaista Ahmed, “Consumers’ Use of Debit Cards: Patterns, Preferences, and Price Response,” Journal of Money, Credit and Banking 40 (1) (2008): 149-172.
  56. Some literature suggests banks have an economic incentive to over-supply ATMs because it increases out-of-network fee use and can be a lead-generation tool. For instance, please see: Dan Bernhardt and Nadia Massoud, “Endogenous ATM Networks and Pricing.” Working paper (2005).
  57. There are other basic financial service fees charged to segments of this group, such as those associated with prepaid cards, short-term loans, and wiring money abroad, but in this section we focus on check cashing and bill payments because these are the two most basic and widely used fee-based services within this group. Please see Fellowes and Mabanta, “Banking on Wealth: America’s New Retail Banking Infrastructure and Its Wealth-Building Potential” for a detailed analysis of the location of non-bank retail outlets.
  58. For a full list of state check-cashing fees, please see: Fellowes and Mabanta, “Banking on Wealth: America’s New Retail Banking Infrastructure and Its Wealth¬Building Potential.”
  59. Fellowes and Mabanta, “Banking on Wealth: America’s New Retail Banking Infrastructure and Its Wealth¬Building Potential.”
  60. Estimates of the unbanked market and its spending are based on proprietary models owned by The Pew Charitable Trusts’ Safe Banking Opportunities Project. We rely on both survey and external data to estimate the size of this market because of the difficulty associated with reaching unbanked households for telephone surveys. While the survey controls for this difficulty, we deemed the average of the two estimates (6 percent and 18 percent) to be a more appropriate measure.
  61. We considered running a structural equation model to determine different latent variable groupings, but concluded that it would be too difficult for industry to replicate this analysis with the available data. We also were unsure how industry would be able to find the latent variable groupings in the market with the available data. Further analysis is needed with data that are available to industry, such as an individual’s credit score, geography, employment, and so on.
  62. For instance, please see: Ellen Seidman, Moez Hababou, and Jennifer Kramer, “Getting to Know Underbanked Consumers: A Financial Services Analysis” (Chicago: Center for Financial Services Innovation, 2005).
  63. For instance, please see: Seidman, Hababou, and Jennifer Kramer, “Getting to Know Underbanked Consumers: A Financial Services Analysis.”
  64. For a recent discussion of this research, please see: Blank, “Public Policies to Alter the Use of Alternative Financial Services among Low-Income Households.”
  65. For a discussion of this research, please see Fellowes and Mabanta, “Banking on Wealth: America’s New Retail Banking Infrastructure and Its Wealth¬Building Potential.”
  66. Fellowes and Mabanta, “Banking on Wealth: America’s New Retail Banking Infrastructure and Its Wealth-Building Potential.”
  67. Please see section on overdrafts for a review of these fees.
  68. Unbanked spending estimates are based on a proprietary model owned by the Pew Charitable Trusts’ Safe Banking Opportunities Project.
  69. The economics of these products are often not attractive today for either financial institutions or consumers, curbing broad adoption. See, for instance, James C. McGrath. 2007. “General-use prepaid cards: the path to gaining mainstream acceptance.” No 07-03, Payment Cards Center Discussion Paper from Federal Reserve Bank of Philadelphia.
  70. Fellowes and Mabanta, “Banking on Wealth: America’s New Retail Banking Infrastructure and Its Wealth-Building Potential.”

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