ABA offered several recommendations for improving the FDIC’s proposed survey on small business lending. Although the FDIC proposed including consumer bank account questions in the survey in order to capture bank efforts to reach underbanked customers, ABA recommended that the FDIC split the survey into two surveys for greater clarity and accuracy.
For the consumer account-related questions, ABA advised the FDIC to include additional response options to reflect the nuances and flexibility in how banks serve customers. The association also asked the FDIC to consider well-founded research on why consumers choose to engage, not engage or partially engage with the banking sector, noting that only a small percentage do not have an account because of costs or past mismanagement of an account, the areas the FDIC’s proposed survey focuses on.
Read the recommendations.