Post Financial Reform Checking: Fee, Free or Wait and See?

With August 15 in the rear view mirror, the impact of the new regulations around overdraft protection (Reg E) are beginning to be played out in the marketplace. While most of the larger banks, such as Bank of America, Chase and Wells Fargo have declared an end to free checking without stipulations, most small and some regional banks such as US Bank, Suntrust and Capital One have left the product unchanged while many of the large regionals such as PNC, KeyBank and others appear to be adopting a wait and see approach.

In fact, according to research released this week from Moebs Services, only 63.6 percent of the largest banks currently offer free checking compared to 92.6 percent in 2009, while community banks’ use of free checking declined only declined from 78.3 percent to 71.7 percent.
As an industry, the offering of free checking dropped by 11 percent over the past year according to the study. This differential based on the size of organization may reflect the desire of the largest banks to improve the cost structure of their checking portfolio, while the offering of free by smaller banks may be a competitive repositioning of the free checking account as a possible counter to the national branch network advantage of the larger banks.

As I discussed in a BAI webinar this week entitled, Checking 2.0: Revenue Opportunities in a New Regulatory Environment, with the cost of maintaining a checking account being several hundred dollars a year, it appears that free checking, along with rewards programs and other benefits, could be the first major consumer banking casualty, as many banks reevaluate their checking continuum in the wake of the government’s financial reform.

But, is getting rid of free checking a good strategy? According to most research, free checking still has a strong appeal across virtually all demographic and economic segments. It even has a positive contribution margin (including the impact of Reg. E, Durbin and the current interest rate environment) when you remove shell accounts with little or no activity. Would it be better to eliminate some of the perks that have been added over the past few years such as free competitive ATM transactions? Many banks are also beginning to charge an annual fee for their rewards program after a first year fee waiver for their programs. Still other firms are considering removing rewards program offerings from their entry level free checking program.

Another way to offer a free product within your checking continuum is to offer free accounts only to customers opting for totally electronic accounts (ATM deposits and withdrawals, online statements and billpay) or to your most active or high balance customers. Bank of America is testing and electronic based checking account currently, where all fees can be avoided if the customer opts for electronic statements and does not use the branch for routine transactions. With a mobile banking customer base of over 4 million households, I suspect there is a strong appeal for this structure of product.

What is clear is that most institutions are reviewing the economics of this product offering and are doing extensive consumer and product research to build a new set of needs based products that are driven by the transaction and money management behavior of their customer base. They are attempting to move towards a stronger set of value based products with enhanced features and benefits while eliminating fixed costs that are associated with low margin (inactive) accounts to improve portfolio profitability.

Has your organization decided whether to offer free checking going forward? Have you introduced new products with enhanced benefits for a fee? Have you considered changing your rewards program? I would be interested in your thoughts.