Our Position

Financial Inclusion for Underserved and Unbanked Individuals


  • ICBA supports community banks’ development and use of technology to more effectively and efficiently provide access to financial services and education for existing and potential customers.
  • Guidelines developed for loan products and services for underserved and unbanked individuals should be easily understood by bankers and flexible enough to be adaptable to various markets and operations.
  • To expand the availability of affordable products for consumers, it is important to identify barriers to their use, including regulatory and statutory obstacles that may discourage development of these products. Solutions should be created on an interagency basis.
  • ICBA supports voluntary, effective financial education. Increasing financial literacy protects consumers, fosters financial stability, and benefits individuals, underserved communities, and our nation as a whole.
  • ICBA strongly urges the CFPB not to issue new prescriptive requirements that would disrupt the traditional data and business models that community banks have long employed to safely and soundly make credit decisions.
  • ICBA welcomes the interagency guidance on the use of alternative data in credit underwriting, but stresses that field examiners must continue to give banks leeway to find innovative ways to provide credit to unserved and underserved consumers. (See “Credit Reporting” resolution.)
  • ICBA is supportive of voluntary efforts to promote affordable insured transaction and savings accounts, such as FDIC’s #GetBanked initiative, in which ICBA and many community banks participate


Financial Health. Only 30 percent of Americans are spending, saving and borrowing in a manner that indicates a financially healthy life. However, community banks are in an optimal position to help consumers improve their financial lives. Community banks are relationship-based providers of financial services and understand the unique situations of the members of their communities, including underbanked consumers.

Technology. Individuals with little or no relationship with a bank may struggle to manage their funds effectively and to save, prepare, or borrow for emergencies. Technology can play a role in raising awareness among such individuals of available products and services and providing access to them.

Affordable Products. Many community banks offer various affordable loan and deposit products and services to their customers. ICBA welcomes opportunities to expand ways to serve new, existing, and potential customers, but guidelines must be simple, easily understood by bankers and examiners, and flexible enough to allow individual community banks to adapt them to their own market and operations.

Overly proscriptive requirements could add to burdens and costs and have the unintended consequence of discouraging these types of products.

Staff Contact

Michael Emancipator

Senior Vice President and Senior Regulatory Counsel

Washington, DC