ChexSystems

ChexSystems

ChexSystems is a financial service that helps banks and credit unions identify customers who may pose a risk to the institution. The service provides a database of information on consumers who have been reported for fraudulent or abusive behavior.

This information helps financial institutions make informed decisions about approving new accounts, issuing loans, and extending credit lines. ChexSystems also offers fraud monitoring and loss prevention services to its clients. In recent years, the company has expanded its services to include identity theft protection and credit monitoring. ChexSystems is a valuable resource for banks and other financial institutions looking to protect themselves from fraud and abuse.

How does ChexSystems work?

Banks and credit unions use ChexSystems to screen new applicants for checking and savings accounts. When you apply for a new account, the bank will run a check on your name through ChexSystems. If your name shows up in their system, the bank may decide to deny your application. 

You can get negative information on your ChexSystems report if you:

• Write a bad check (one that bounces because there isn’t enough money in your account to cover it) 
• Have an outstanding debt with a bank (for example, if you overdrew your account and didn’t repay the debt) 
• Give false information on a credit application 
• Have had an account closed by a bank for cause (such as writing bad checks or engaging in fraudulent activity) 

What to Do If You’re Listed in ChexSystems?

If you’ve been listed in ChexSystems, it may be challenging to open a new checking or savings account. However, there are a few steps you can take to improve your chances of getting approved for an account.

First, order a copy of your ChexSystems report and make sure that all of the information is accurate. If there are any mistakes, file a dispute with ChexSystems. It would be best if you also tried to open an account with a credit union or a bank that doesn’t use ChexSystems.

Finally, keep in mind that it may take some time to get approved for an account, so be patient and don’t give up.

How Often Can You Get a Free Copy of Your ChexSystems Report?

Consumers can obtain a free copy of their ChexSystems report once every 12 months. ChexSystems is a consumer reporting agency that provides information on consumers’ banking history, including information on any negative actions such as bounced checks or overdrafts.

To request a free copy of your ChexSystems report, you’ll need to contact ChexSystems directly and provide some personal information, such as your name, address, Social Security number, and date of birth. It’s important to review your ChexSystems report periodically to make sure that the information it contains is accurate. If you spot any errors, you can file a dispute with ChexSystems to have the incorrect information removed from your report. 

How Do You Know If You Have a ChexSystems File?

There are a few ways to find out if you have a ChexSystems file. You can request a free copy of your report from ChexSystems, or you can ask the bank if they use ChexSystems when you apply for an account. If you are denied an account, the bank is required to provide you with notice that ChexSystems was used in the decision.

How to use this report?

Your ChexSystems report is an essential tool that can help you understand your financial history and make informed choices about your future. Here’s how to use it:

First, check for any errors or negative information that may be inaccurate. If you find anything that doesn’t look right, dispute it with ChexSystems.

Next, take a look at your account balances and transactions over time. This will give you a good idea of your spending patterns and whether you’re generally able to keep up with your bills.

Finally, focus on the positive information in your report. This may include things like on-time payments and low account balances. Use this positive information to help you make decisions about applying for new credit products or increasing your credit limits.

How to dispute the information in your report?

If you have been reported to ChexSystems, it is essential to dispute any inaccurate or outdated information in your report. You can do this by contacting ChexSystems directly and providing supporting documentation.

In most cases, ChexSystems will investigate your dispute and remove any incorrect information from your report. However, if you are still having difficulty securing a new account, you may need to contact a consumer law attorney for help.

How long do you stay on ChexSystems?

ChexSystems is a database that financial institutions use to track negative account information. This information includes things like overdrafts, bounced checks, and unpaid fees. Financial institutions report this information to ChexSystems, and it can stay on your record for up to five years. However, the length of time it remains on ChexSystems may vary depending on the severity of the offense.

Are credit reports part of the review process?

When you apply for a new bank account, the bank will likely review your ChexSystems report. This report includes information on your past banking history, including any bounced checks or overdraft fees. The bank will use this information to decide whether or not to approve your application.

However, your credit report is not part of the ChexSystems review process. The two reports are separate and serve different purposes. Your credit report is a record of your financial history, including any outstanding debts or late payments.

The bank will not review your credit report when considering your application for a new account. However, if you have a poor credit history, it may make it more difficult to get approved for an account.

Does a ChexSystems Report Affect Your Credit Score?

No, a ChexSystems report does not affect your credit score. However, if you have a negative item on your ChexSystems report, it may make it more challenging to get approved for new credit products. For example, if you apply for a new credit card and are denied, the credit card company may tell you that your ChexSystems report was a factor in the decision.

What Rights Do I Have When Dealing With ChexSystems?

If you have been denied a checking account because of information in your ChexSystems report, you have certain rights under the Fair Credit Reporting Act (FCRA). ChexSystems is a consumer reporting agency that keeps track of negative information related to checking and savings accounts, such as bounced checks and account closures. Consumers who have been reported to ChexSystems may find it difficult to open a new account.

Under the FCRA, you have the right to obtain a free copy of your ChexSystems report from the agency. You also have the right to dispute any inaccurate or incomplete information in your report. If you prevail in your dispute, the FCRA requires ChexSystems to delete incorrect information from your report. Finally, the FCRA gives you the right to opt-out of certain types of pre-screened offers for credit and insurance. If you opt-out, companies will not be able to use your ChexSystems report when making these types of offers.

If you believe that ChexSystems has violated your rights under the FCRA, you may file a complaint with the Consumer Financial Protection Bureau (CFPB). You can also file a lawsuit against ChexSystems in federal court.

Can ChexSystems Help Victims of Identity Theft?

Identity theft victims may find themselves with negative marks on their ChexSystems report, which can make it difficult to open a new bank account. In some cases, a victim’s entire financial history may be wiped out by the identity thief. Fortunately, ChexSystems offers a few options for victims of identity theft.

First, victims can file a police report and provide ChexSystems with a copy. This will help to distinguish between legitimate and fraudulent activity on the account.

Victims can also place a fraud alert on their report, which will notify banks and other financial institutions to take extra precautions when handling the account.

Finally, victims can request a free copy of their report to check for accuracy. By taking these steps, identity theft victims can help protect their financial future

What Is ChexSystems?

ChexSystems Inc. (commonly referred to as
ChexSystems) is a consumer reporting agency
that tracks people’s banking histories. Financial
institutions report information about customers
to ChexSystems, and then ChexSystems compiles
and reports that information back to financial
institutions for a fee. Banks rely on this information

to screen prospective clients and, theoretically, to
prevent account fraud. ChexSystems is governed
by the Fair Credit Reporting Act and shares
similarities with credit reporting agencies like
Equifax and Transunion. However, unlike traditional
credit reporting agencies, ChexSystems reports
mostly negative information, such as involuntary

account closures. An estimated 80 percent of
all banks and credit unions use ChexSystems or
other consumer reporting agencies such as Early
Warning Services to decide whether to allow a
customer to open a checking or savings
account.vii
Reports compiled by ChexSystems include
information on customers’ banking history:
involuntary account closures and inquiries.
Involuntary account closures occur when a bank
or credit union forcibly closes a client’s account,
typically because of overdrafts or other “account
mismanagement.” Generally, records of account
closures remain on a report for five years.viii
Involuntary account closures are reported in
ChexSystems either as closures for (1) account
abuse or (2) suspected frauded depending on the
severity of the action and the account holder’s
motivation. Banks have discretion to select the
reason for account closure, and distinctions
aren’t clear (this issue is discussed in greater
depth below). However, based on conversations
with ChexSystems and financial institutions, the
following rough definitions emerged:

Account Abuse typically involves account
mismanagement and unpaid debt on an
account without intention on the consumer’s
part to misuse the account for financial or
personal gain. Bank policies vary, but a record
for account abuse will typically result in a

consumer being unable to open a new account
for five years unless they pay their debt.

Suspected Fraud typically involves suspicion
of intentional misuse of an account for
financial or personal gain. Since it is deemed
more severe, a record for suspected fraud
typically results in consumers being unable to
open a new account for five years regardless of
whether the debt is repaid.
The second component of a ChexSystems report
is inquiries. Inquiries signify that a consumer has
applied for a financial product, like a bank account
or payday loan, though they do not represent actual
use of the product. Like account closures, inquiries
are separated into two categories: demand deposit
account (DDA) inquiries and non-demand deposit
account (non-DDA) inquiries.
Demand deposit account (DDA) inquiries
include details on a consumer’s applications
for checking or savings accounts.
Non-demand deposit account (non-DDA)
inquiries include details on a consumer’s
application for financial products outside of
traditional bank accounts, such as payday loans,
installment loans, auto title loans, and more.
The following figure outlines the components of a
ChexSystems report.

Key Issues Identified With Chexsystems

While individual banks and credit unions utilize
ChexSystems in a way they consider to be neutral
to prevent fraud and manage risk, OFE’s research
revealed systemic issues in both ChexSystems’
design and implementation, resulting in significant
confusion and unfairness and ultimately undue
exclusion for low-income consumers, and in
particular Black consumers. The four main
problems uncovered through our research and
interview process include:

Unclear, Unfair and Unequal Treatment –
individuals do not understand why they have
a record and banks choose to close accounts
and categorize those closures in an arbitrary,
unfair, and unequal manner
Ambiguous Impact of Inquiries – inquiries
should not count against consumers and
prevent consumers from opening accounts,
but they appear to

Impossible Resolution – it is nearly impossible
for a consumer to resolve a ChexSystems
record via a dispute and resolution via debt
repayment varies from bank-to-bank with
limited information available to consumers
Individual Impacts, Systemic Exclusion –
ChexSystems records worsen individuals’
financial vulnerabilities and have a
disproportionate impact on Black consumers
The impacts of ChexSystems records are tangible,
devastating, and widespread in San Francisco
and across the country. Individuals are faced with
unintelligible and unfair outcomes and are unable to
escape the system. Taken together, these individual
cases result in a system that is mostly unknown,
indecipherable, and inequitable, and results in
systemic exclusion from the financial mainstream
for the clients OFE is most dedicated to serving.

Unclear, Unfair and Unequal Treatment

ChexSystems is utilized within an almost
completely opaque system, which allows banks
to report and categorize involuntary account
closures in arbitrary, unfair, and unequal ways. In
most instances, individuals do not understand that
they have a ChexSystems record or the reason

behind that record. Banks are afforded almost
complete discretion regarding involuntary account
closures, including the rationale for the closure
and the type of closure reported to ChexSystems.
This discretion results in unfair outcomes, where
unwitting and good faith activity can be considered

and reported as suspected fraud or account abuse.
Additionally, lack of definitional clarity results in
unequal outcomes, where similar activity can be
categorized as either suspected fraud or account
abuse, and financial institutions may use the debt
owed as a proxy for severity of the offense.

Unclear Records – People do not know
they have ChexSystems records

A primary issue OFE uncovered with ChexSystems
records is that there is little-to-no consumer
understanding or awareness of the system or
its implications. While 25 percent of financial
coaching clients whose records were reviewed
had an involuntary account closure reported to
ChexSystems, very few of these clients knew about
this record or understood how it could impact
them in the future. Once people learned about the
record from a financial coach, most were still not
clear about the exact activity that resulted in the
account closure and ChexSystems record.

Unfair Treatment – Good faith activity can
result in ChexSystems records

Though ChexSystems records ostensibly are used
to prevent fraud and root out malicious consumers,
the majority of records result from repeated
overdrafts or other unwitting or good faith
behavior. OFE’s research found numerous clients
who had their accounts closed due to repeated
overdrafts or because they were victims of fraud or
even because of bank error.
Most ChexSystems records result due to overdraft
or non-sufficient fund transactions – which occur
when a consumer does not have enough money in
their account to cover a transaction, but the bank
processes it anyway, leading to a negative account

balance – rather than fraudulent behavior. One 2008
study found that 97.5 percent of account closures
reported to ChexSystems were due to overdrafts.ix
Overdraft practices are highly profitable to banks
– with banks earning an estimated $11 billion in
overdraft fees in 2019x
– and banks’ own practices
and account structures can contribute to the
prevalence of repeated overdrafts and involuntary
account closures. Closures triggered by overdraft
are often the result of outstanding unpaid debt that
consists mostly of fees, which dwarf the actual
amounts withdrawn and represent profit rather
than loss recovery for banks.xi
Though a comprehensive discussion of overdraft
is beyond the scope of this report, there are
numerous issues with the overdraft system:
banks pressure consumers to open accounts with
overdraft enabled and then impose high fees;
banks re-order transactions from high-to-low to
maximize fees (a practice now banned for banks
regulated by the FDIC). Overdraft fees and resulting
account closures can be devastating for clients,
but they are also entirely preventable and within
banks’ control. Many accounts, such as Bank Oncertified accounts, simply do not permit negative
balances.

For example, a client in a bank had his account
closed due to suspected fraud after a bank error.
Ironically, this ‘suspected fraud’ label technically
fits, because though he was completely absolved,
the bank at one point incorrectly believed he had
committed fraud. This inaccuracy is particularly

galling because a label of suspected fraud implies
the presence of criminal activity, whereas banks
do only limited (if any) due diligence to investigate
and confirm the suspected fraud before reporting
it to ChexSystems.

Unequal Treatment – Similar activity
results in different labels and outcomes

Unlike the three national credit reporting agencies
(Equifax, Transunion, and Experian) which use
relatively standard definitions for credit issued,
monthly payments and debt in delinquency,
ChexSystems lacks clear definitions for “suspected
fraud” and “account abuse.” The system offers
limited guidance for how financial institutions
should delineate between the two when categorizing
the reason for an involuntary account closure

though interviews with stakeholders, including
ChexSystems itself, indicated that the difference
arises based on the accountholder’s motivations and
intentionality. This lack of clarity provides banking
institutions and even individual bank branches
with nearly unfettered discretion in how to define
and apply these terms, leading to opaque internal
practices and industry-wide inconsistencies.
For example, through interviews, OFE found that
similar or even identical customer banking activity
can be categorized in different ways, depending

on the financial institution involved. In the stories
below, two clients unknowingly deposited bad
checks and withdrew the funds before the checks
cleared. Both were victims of fraud. However, one
incident was labeled suspected fraud and the other
was labeled account abuse. This inconsistency
is particularly troubling given that closures for
suspected fraud have harsher implications than
those for account abuse.

Without clear definitions, institutions may
use irrelevant proxies, such as debt owed to
the institution, rather than the type of activity
or motivation behind the activity to delineate
between suspected fraud and account abuse. One
financial coach with over ten years’ experience
in the financial services industry noted that, in
their experience, once a client’s debt to a financial
institution exceeds approximately $400 the

account closure is typically labelled as suspected
fraud rather than account abuse.
OFE’s limited review of clients’ ChexSystems
records corroborates this coach’s experience.
Nine of the 11 clients flagged for account abuse
owed debt of $400 or less and all 11 owed debt
under $600. In contrast, in accounts flagged for
suspected fraud, five out of the seven owed debt
greater than $400. There is no reason that the
determination of suspected fraud should hinge on
the dollar value of the transaction. An individual
could owe $4,000 to a bank or credit union in
good faith if they were the victim of fraud or could
purposefully and intentionally defraud a bank of $40.
Using a debt threshold to define suspected fraud
is fundamentally inaccurate and will necessarily
result in inconsistent and unequal results.

Offering Safe, Overdraft-Free Accounts
Should Eliminate Need to Use
ChexSystems

In addition to this unclear, unfair and unequal
treatment, there are certain situations where
ChexSystems is simply unnecessary. Financial
institutions assert that they use ChexSystems
and other account screening agencies in order to
mitigate risk of fraud and loss. However, many banks
and credit unions currently offer Bank On certified
accounts that meet national standards for safety
and affordability. These accounts are overdraft free, meaning that they limit the occurrence of any
negative balances. This not only protects account
holders from overdraft fees but also protects
financial institutions from financial losses. Financial
institutions should not be creating unnecessary
barriers where their own financial risk has already
been hugely mitigated, if not eliminated.

Ambiguous Impact of Inquiries

Aside from the involuntary account closures, that we have analyzed in the previous paragraphs of this article,
ChexSystems also collects and reports on inquiries.
This inquiry information is purportedly neutral
but appears to be used at times to deny clients’
accounts. As noted above, ChexSystems records
consumer inquiries for demand-deposit bank accounts (DDAs) at traditional financial institutions
as well as inquiries for loan products, like payday,
installment, or auto title loans from fringe financial
services (non DDAs). Inquiries reflect interest in
and applications for financial products not actual
use of these products. Many consumers shop

around, submitting multiple applications for payday
loans, and some may ultimately decide against
moving forward with any loan.
ChexSystems staff stated that inquiries should
be viewed neutrally and should not be utilized for
banking decisions, which makes sense because
inquiries reflect mere interest and not utilization

and are irrelevant to banking history and fraud.
Similarly, no banks or credit unions interviewed
for this report indicated that inquiries play a
role in decisions around bank account access.
Nevertheless, OFE found instances, including
R.A.’s example below, where financial institutions
appeared to use past inquiries to deny a consumer
a bank account.

Given the prevalence of fringe financial products,
even limited account denials due to inquiries can
have significant impacts. Nationwide 12 million
people take out payday loans each year,xii and of
the ChexSystems reports reviewed by OFE, over
50 percent had at least one inquiry, meaning they
could be at risk for an account denial. Aside from

the inherent irrelevance, denials based on inquiries
are particularly pernicious because they create a
vicious cycle with consumers who are denied bank
accounts due to inquiries driven further from the
financial mainstream and forced to rely more on
fringe financial products.

Impossible Resolution

Once a client has an involuntary account closure
on their record, it is essentially impossible to
successfully dispute and clear this record due to the
structure of the system. There are two ways in which
a consumer can theoretically resolve a negative
ChexSystems record and re-enter the financial
mainstream: by disputing their ChexSystems record
or by paying back debt owed to the former financial
institution (though the latter is generally only

available for account abuse and not suspected fraud).
However, even experienced and savvy financial
coaches struggle to dispute clients’ ChexSystems
records due to a general lack of information and
the information and power asymmetries between
the accountholders and the bank. Moreover, while
paying back debt can work to resolve records in some
instances, banks have inconsistent and unpublished
policies regarding what a client must do to access

a bank account after an involuntary account
closure, leading to confusion.

Virtually impossible to resolve a record
via dispute process

ChexSystems theoretically offers a dispute process
where consumers can “submit a dispute directly to
the source of the information” (the bank or credit
union) or ChexSystems can “contact the source on
your behalf to initiate an investigation.”xii However,
the automatic and immediate nature of account
closures as well as information asymmetries makes
it difficult, if not impossible, for consumers and even
financial coaches to successfully dispute a record
for account closures. Once a financial institution has
closed an account, clients immediately lose access
to their banking records and history, including
crucial information such as their bank account
number. Even if consumers have sufficient details
to request more information about the closure,
financial institutions are not required to provide
any details about the activities that led to the
closure, leaving accountholders to guess the
rationale. And even if clients know exactly which
transactions to dispute, they still face an uphill
climb as the burden is on them to prove a negative:
the lack of suspected fraud or account abuse.
OFE’s research and experience with financial
coaching underscores the difficultly of disputing
these records. Of the ChexSystems reports
reviewed by OFE, none offered details for why the
account was closed beyond the closure category.
Even veteran financial coaches struggle to get
information, let alone relevant documentation,
from banks when following up on a client’s record.
One coach noted that if he needs details, he
typically sets up a meeting with a bank’s senior
executive to ensure he gets some information, a
practice that is neither scalable nor sustainable.
The dispute process is so time-consuming and
unlikely to succeed that coaches typically set up
clients with alternative products, such as prepaid
cards, while tackling a dispute. Despite working
extensively on ChexSystems for over a year, OFE
and its financial coaching program have only
successfully disputed and wiped clear one client’s
ChexSystems record (R.S., the client wrongfully
accused of suspected fraud). The resolution process

took a total of two months and was only successful
after Treasurer’s Office staff reached out to bank
leadership. After witnessing the challenges faced
by professional financial coaches in this process,
it is nearly impossible to imagine a consumer
successfully disputing a record on their own.

Limited details on how to resolve records
and reopen accounts via repayment

Aside from disputes, consumers can sometimes
resolve a ChexSystems record and re-open an
account by paying off existing debts, but this
process is variable and not publicized. While
banks rarely if ever offer accounts to people with
ChexSystems records for suspected fraud, many
banks do offer options for people with account
closures due to account abuse, typically under the
condition that they first repay their debt. However,
banks provide essentially no public details on how
to bank with a ChexSystems record, and policies
vary widely bank-to-bank, meaning consumers are
unaware of this option. This lack of information is
even more pronounced for low-income customers,
people of color and immigrants who may struggle
to navigate the banking system even without the
burden of a ChexSystems record.
To create a non-dispute driven resolution process
for clients with ChexSystems records, OFE surveyed
banks and credit unions that participate in our local
Bank On program regarding their ChexSystems
procedures, including their policies for banking
people with prior ChexSystems records. These
financial institutions, which included multi-national
banks, regional banks, and credit unions, all offered
a process for clients with account abuse records
to open an account, but their requirements for
repayment varied widely. For example, while some
institutions require a client to repay debt regardless
of the amount or where it is owed, another required
repayment only if the debt was owed to the
institution itself or if it was above a certain dollar
threshold. Notably, only one institution, Mechanics
Bank, provided a second chance account for
clients with records for suspected fraud so long
as they submit a letter from a local financial coach
demonstrating efforts to change their behavior. This
account has been a lifeline for OFE’s clients.

XX

Treasurer José Cisneros and the Office of Financial Empowerment
(OFE) launched the groundbreaking Bank On San Francisco program
nearly 15 years ago after realizing that many residents of San Francisco
had no bank account (“unbanked”), and instead relied on costly fringe
financial products such as payday lenders and check cashers. Bank On
San Francisco spurred a national movement and a national coalition
of cities working to improve access to safe and affordable bank
accounts for all who desire and need one. Bank On San Francisco
boasted strong initial success, with unbanked rates dropping from an
estimated 15-20 percent in 2005i
to 2.8 percent in 2019.ii
However, unbanked rates remain persistently high for certain
populations. For example, 42 percent of Black clients enter OFE’s
financial coaching program unbanked, compared with 32 percent
of clients overall. This local data reflects disparities in mainstream
banking access nationally, as 13.8 percent of Black households
and 12.2 percent of Latinx households were unbanked as of 2019,
compared to only 2.5 percent of white households.iii
According to the Federal Deposit Insurance Corporation (FDIC)’s most
recent survey of household banking practices, slightly more than 50
percent of people who are unbanked had a bank account at some
point in the past.iv With so many previously banked people now
unbanked, it is clear that any effort to reduce unbanked rates must
recognize this constituency and their concerns and needs.
To understand why these individuals are currently unbanked, OFE
embarked on a research initiative to study reasons why people
remain unbanked, including debt collection and bank levies, fears
around asset limits in public benefit programs, and distrust of
mainstream financial institutions. The focus of this follow-up
report is another systemic barrier to banking: the denial of customer
applications by banks based on negative consumer banking data –
especially involuntary account closures – held in the records of bank
account consumer account screening agencies like ChexSystems.
ChexSystems, a subsidiary of Fidelity National Information Services.

Consumer advocates and banking experts
have long expressed concern about these
specialty credit agencies and their use by
financial institutions, including lack of accuracy,
consistency, transparency, proportionality, and
error resolution. Unfortunately, there is limited
data available on the prevalence of involuntary
account closures and ChexSystems records –
which is troubling – but estimates have shown that
the population affected is substantial. A Consumer
Financial Protection Bureau (CFPB) study of
overdraft programs estimated that six percent of
accounts are closed involuntarily per year,v
and
the most recent data OFE was able to identify
suggests that in 2005 up to 19 million people had
ChexSystems records.vi
Building on prior work around ChexSystems –
including an excellent piece on account screening
agencies by the National Consumer Law Center and
the Cities for Financial Empowerment Fund – OFE
sought to examine the issue at a local level in order
to create a resolution process for individuals with
records and to generate suggestions for systemic
reform.

References And Sources

Leigh Phillips and Anne Stuhldreher, “Building Better Bank Ons: Top 10 Lessons from
Bank On San Francisco,” February 2011, available at: https://static.newamerica.org/
attachments/3752-building-better-bank-ons/PhillipsStuhldreherBankOn2-11.71f3e6447
a8d486c998a171835b5f11d.pdf
ii Federal Deposit Insurance Corporation (FDIC), October 2020, “How America Banks:
Household Use of Banking and Financial Services,” available at: https://www.fdic.gov/
analysis/household-survey/2019appendix.pdf.

v Consumer Financial Protection Bureau (CFPB), “CFPB Study of Overdraft Programs:
A white paper of initial data findings,” June 2013, available at: https://files.
consumerfinance.gov/f/201306_cfpb_whitepaper_overdraft-practices.pdf.
vi James Marvin Perez, “Blacklisted: The Unwarranted Divestment of Access to
Bank Accounts,” New York University Law Review, November 2005, https://www.
nyulawreview.org/wp-content/uploads/2018/08/NYULawReview-80-5-Perez.pdf.
vii Chi Chi Wu, National Consumer Law Center (NCLC) and Katie Platt, The Cities for
Financial Empowerment Fund (CFE), “Account Screening Consumer Reporting
Agencies: A Banking Access Perspective,” available at: https://www.nclc.org/images/
pdf/pr-reports/Account-Screening-CRA-Agencies-BankingAccess101915.pdf
viii ChexSystems, “Frequently Asked Questions,” https://www.chexsystems.com/web/
chexsystems/consumerdebit/otherpage/AnswerstoFrequentlyAskedQuestions/.
ix Dennis Campbell, Francisco de Asis Martinez-Jerez, and Peter Tufano, “Bouncing
Out of the Banking System: An Empirical Analysis of Involuntary Account Closures,
December 2008, available at: https://papers.ssrn.com/sol3/papers.cfm?abstract_
id=1335873.
x Center for Responsible Lending, “Overdraft Fees: Banks Must Stop Gouging Consumers
During the COVID-19 Crisis,” June 2020, available at: https://www.responsiblelending.
org/sites/default/files/nodes/files/research-publication/crl-overdraft-covid19-jun2019.
pdf.
xi Consumer Financial Protection Bureau (CFPB), “CFPB Study of Overdraft Programs:
A white paper of initial data findings,” June 2013, available at: https://files.
consumerfinance.gov/f/201306_cfpb_whitepaper_overdraft-practices.pdf.
xii The Pew Charitable Trusts, “Payday Loan Facts and the CFPB’s Impact,” May 2016,
available at: https://www.pewtrusts.org/-/media/assets/2016/06/payday_loan_facts_
and_the_cfpbs_impact.pdf.
xiii ChexSystems, “Dispute Information,” https://www.chexsystems.com/web/
chexsystems/consumerdebit/page/dispute/.
xiv Mehra Baradaran, How the Other Half Banks: Exclusion, Exploitation and the Threat to
Democracy, Harvard University Press, October 2015.
xv Federal Deposit Insurance Corporation (FDIC), “2017 Survey of Unbanked and
Underbanked Households,” October 2018, available at: https://www.fdic.gov/
householdsurvey/2017/2017report.pdf.
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