Community Impact Report Card

Community Impact Report Card

The City of New Haven and

The Community & Economic Development Clinic

at Yale Law School

Acknowledgements

The Community Impact Report Card was conceived of as a joint

project by the City of New Haven and the Community &

Economic Development Clinic at Yale Law School. Visiting

Associate Clinical Professor of Law Raymond Brescia was

responsible for supervising the project during the 2011-2012

academic year. Students involved in the development of CIRC

were: Yale Law School students Lindsey Counts, Su Da,

Elizabeth Kelly, Ming-Yee Lin, Jin-Kang Nah, and Sonia

Steinway; Yale School of Management students David Bisson,

Katy Davis, Liz Greenberg, and Jen Leybovich; University of

Connecticut School of Law Student Bret Kupfer; and University

of Michigan Law School student Seth Mohney. Officials from the

City of New Haven who were instrumental to the project were

the Honorable Mayor John DeStefano, Jr.; Director of

Communications, Elizabeth Benton; Legislative Director,

Rebecca Bombero; and the Executive Administrative Assistant

to the Mayor, Rosemarie Lemley.

Introducing the

Community Impact Report Card

CIRC was designed with two audiences in mind: consumers, who can use the ratings to comparison-shop, and banks, as an impetus to strengthen their product and service offerings. CIRC is also designed to be replicable beyond New Haven; other communities are encouraged to use the CIRC methodology while adapting the index to meet their own local needs.

The central motivating principle behind the project is the belief that

providing consumers with basic information about banking products and services will encourage banks to be more responsive to community needs. This motivating principle was inspired by several beliefs:

• Consumers care about bank practices when choosing where to bank, including fees assessed and local lending practices;

• Consumers will then shop around and choose a bank that offers more flexible and accessible products and services; and

• Banks will respond by striving to improve the range of products and services they offer.

CIRC was designed to reflect the types of products and services that

consumers care about. The data incorporated falls into two basic categories: (1) home loans and (2) banking products & accessibility.

Eleven of New Haven’s banks were rated in this first iteration. Start

Community Bank of New Haven has been excluded: since it opened in 2010, there is insufficient HMDA data to rate it. The Milford Bank has also been excluded because it only operates a loan production office and not a consumer bank branch in New Haven.

All banks were given the opportunity to comment on the data collected for the index. Only two did so, with both providing information about their

respective community development efforts in the city, but without suggesting changes to their CIRC scores.

Goals

• To create a dialogue with banks about best practices in meeting consumer needs

• To inform consumers about the range of products and services available at local banks

Vision

• CIRC was designed to be:

- Locally relevant; - Easily accessible; - Transparent; and

- Replicable in other communities

Bank

Score (Out of 100)

First Niagara Bank

74

Bank of America

73

People's United Bank

68

JPMorgan Chase Bank

66

Bank of Southern CT

63

Webster Bank

61

RBS Citizens

59

TD Bank

59

Citibank

56

Sovereign Bank New England

56

Wells Fargo Bank

53

Start Community Bank

NA

The Results

Banks’ total scores were calculated based on their scores in two categories: (1) home loans, worth a total of 30 points, and (2) banking products & accessibility, worth a total of 70 points.

(1) Home Loans

Home Loans: Categories Included

Home Loans: Points Allocated

All data used in the Home Loans category was collected by the Federal Government under the Home Mortgage Disclosure Act (HMDA)

regarding lending practices in the City of New Haven. Data was collected for 2010 for the City and County of New Haven.

• Percent of home loan applications accepted – all applicants; • Percent of loan applications accepted – Latino applicants; • Percent of loan applications accepted –Black applicants;

• Percent of loans made to applicants with incomes below the county average of $78,000;

• Percent of loans made in the City of New Haven compared to New Haven County;

• Total value of loans made in New Haven compared to nationally.

There is no ideal or paradigmatic percentage in each of the categories included. There is no set benchmark on the number of loans that banks should approve, nor is every loan applicant qualified for approval. That said, without assessing every application, there can be no determination as to whether the banks in the sample were approving too many or too few loans. The study therefore relies on the median for the sample set (11 banks) in each category as a guiding benchmark. Points were assigned as follows:

Because there were six categories, there were 30 points available in the Home Loans category.

3 points

1 point 5 points

-20% of median _Median +20% of

Home Loans: 30% of the index

Home Loans: Categories Not Included

Loan approval rate by gender was also calculated for each bank, but there was little difference between acceptance rates of male and female applicants at any of the banks assessed.

The 20% range was based on consultation with experts in the community banking field, but to ensure accuracy, sensitivity analyses were run

around that range. Results did not change if either a lower threshold (15%) or a higher one (25%) were used– the banks had the same relationship to each other, and no bank’s score changed more than 2 points.

Banks reporting no relevant applicants (i.e., for the Latino and Black loan acceptance ratio) were assigned 1 point, as it was considered

problematic that they failed to attract even one loan candidate of that race or ethnicity during the relevant time period. In the sample, only one bank reported no Latino or Black applicants.

Home Loan Info

Min

Median

Max

Loan acceptance – All 33% 56% 100%

Latino loan acceptance 0% 29% 67%

Black loan acceptance 0% 36% 67%

Low income as % of loans 31% 50% 85%

City v. County 3% 7% 57%

New Haven v. national 0.0% 0.1% 52%

Home Loans: Overall Results*

*One bank reported four loan applications in 2010, and approved all four. Of banks that approved no Latino or Hispanic applicants, one reported two applications; another bank reported eight. One bank reported no Latino or Hispanic applicants. One bank reported six Black or African American applicants, but did not approve any. One bank reported no Black or African American applicants.

(1) Home Loans: Results by Bank

Bank Loan accept ance Latino accept ance Black accept ance Low income loan % City vs. County New Haven v. Nat’l Median 56% 29% 36% 50% 7% 0.08% Bank of America 67% 58% 64% 46% 7% 0.02% Bank of

Southern CT 100% applicant No applicant No 75% 57% 52.11%

Citibank 39% 36% 32% 85% 6% 0.01% First Niagara 55% 26% 46% 69% 11% 1.22% JPMorgan Chase 74% 67% 67% 60% 5% 0.01% People’s United 58% 32% 47% 56% 9% 1.13% RBS Citizens 57% 20% 0% 35% 10% 0.17% Sovereign Bank 50% 0% 25% 38% 4% 0.03% TD Bank 33% 0% 20% 31% 7% 0.08% Webster Bank 56% 20% 33% 43% 3% 0.52% Wells Fargo Bank 42% 43% 38% 50% 4% 0.01% 3 points 1 point 5 points

(2) Bank Products & Accessibility

Bank Products: Categories Included

Information was gathered from banks’ websites, customer service

telephone hotlines, and site visits conducted during Spring 2012. Site visits were typically conducted at one branch or ATM per bank. Since none of the information collected was proprietary or confidential, callers were seldom asked to identify the reason for their questions. However, to the extent that bank representatives inquired, the callers identified themselves as academic researchers. The data collected thus represents the

information available to New Haven consumers.

A. Physical accessibility: Data related to physical branch locations in the City of New Haven;

B. ATM locations and features: Number and location of bank ATMs in New Haven, including any ATMs affiliated with banks (e.g., those located in CVS Caremark stores or gas stations), as long as the bank advertised the ATM as “in-network”;

C. Personal savings accounts: Assessment of each bank’s most basic savings account offered (i.e., those with the lowest minimum opening balance requirements);

D. Personal checking accounts: Assessment of each bank’s most basic checking account offered (i.e., those with the lowest minimum opening balance requirements or fewest service offerings);

E. Small business accounts: Assessment of each bank’s most basic offering, typically designed for truly small, local businesses; F. Other: Acceptance of Elm City Resident Card or alternative

identification, personal loan options, check cashing services for non-customers, and alternative products offered.

Most of the banking products categories were rated on a 1-3 scale, although two were graded on a binary scale (1-2 points). There were 70 points available in the Bank Products category.

Bank Products: Categories Not Included

Data in seven additional categories were collected, but there were no

meaningful differences between banks in these areas. At the same time, in many of these categories, it appears that the banks are engaged in

practices designed to enhance consumer accessibility to banking products and services:

• Proximity to public transportation; • Free direct deposit;

• ATM services (e.g., ATM accepts deposits);

• Usage criteria for personal savings accounts (e.g., number of transactions permitted per month);

• Usage criteria for personal checking accounts; • Check cashing for account holders;

• Small business accounts opening criteria.

Bank Products: Overall Results

Bank Products Info

Min

Mean

Max

Total

A. Physical accessibility 8 10.1 12 14 B. ATM locations & features 8 9.2 12 15 C. Personal savings accounts 3 5.5 8 9 D. Personal checking accounts 5 6.7 10 12 E. Small business accounts 4 5.5 8 9

Physical Accessibility:

Points Allocated

Physical Branch Locations: Number of branches located in the

City of New Haven.

Geographic Distribution: Number of branches located in U.S.

Dept. of Housing and Urban Development’s previously

designated Empowerment Zones. HUD designated

Empowerment Zones on the basis of economic distress, defined

as high levels of poverty, low median family income, and high

unemployment. Each bank’s branch location(s) were mapped

using HUD’s online Empowerment Zone locator.

Opening Hours: Consumers may have difficultly accessing

banking services if their banks are only open during standard

working hours (defined as Monday to Friday, 9 AM to 6 PM).

Accordingly, the study assessed whether the banks in the

sample had at least one branch in the City of New Haven that

is open during non-standard hours.

Online or Mobile Banking: Online and mobile banking capacities

can provide significant convenience for consumers. The study

assessed each bank’s free online or mobile capabilities,

including the ability to pay bills online.

2 branches

1 branch 3+ branches

2 branches

0-1 branch 3+ branches

Sat. or PM

No Sat. or PM Both Sat. + PM

A. Physical Accessibility Points Allocated

Multilingual Staff: Offers staff members who speak languages

other than English.

According to the U.S. Census Bureau, 32.7% of New Haven

residents speak a language other than English at home. It

would therefore be reasonable to expect banks to accommodate

this large segment of their consumer base by providing services

in language other than English.

Because data in this category was collected through site visits,

the presence of staff members who spoke languages other than

English represents bank’s actual practices rather than official

policies, if they differ. It therefore cannot be certain that a

bilingual staff member will be present during all open hours at

any given bank, nor that the presence of a bilingual staff

member represents official bank policies with respect to offering

services in multiple languages. However, it can reasonably be

assumed that banks were cognizant of language ability in hiring

employees and in advertising their language proficiencies.

Eng. + Spanish

Physical Accessibility:

Results by Bank

Mean 2.73 1.55 N/A N/A N/A

Bank of

America 6 4 Saturday Yes Eng. + Span. Bank of

Southern CT 2 1 Saturday Yes Eng. only Citibank 1 1 Saturday Yes Multiple First Niagara 4 2 Saturday Yes Eng. + _Span. JPMorgan

Chase 2 2 Saturday Yes Eng. + Span. People’s

United 3 2 Sat. + nights Yes Eng. + Span. RBS Citizens 3 1 Saturday Yes Eng. + _Span. Sovereign

Bank 2 1 Saturday Yes Eng. + Span. TD Bank 2 0 Sat. + _nights Yes Eng. + _Span. Webster Bank 2 2 Saturday Yes Multiple Wells Fargo

Bank 3 1 Saturday No Eng. + Span.

2 points

1 point

3 points

ATM Locations & Features:

Points Allocated

ATM Locations: Number of ATMs in New Haven.

Geographic Distribution: Number of ATMs located in HUD

Empowerment Zones (see above).

Multilingual Functionality: ATM offered services in multiple

languages (see above).

Non-bank customer fees: Because CIRC is intended to capture

the overall community friendliness of each bank, fees that

banks charge to non-customers for use of their services have

also been included.

Non-bank ATM fees: Some banks also charged their own

customers for using ATMs not affiliated with the bank.

3-4 ATMS 0-2 ATMs 5+ ATMs <$2 fee >$2 fee No fee 3-4 ATMS 0-2 ATMs 5+ ATMs Eng. + Spanish

Eng. only 3+ languages

<$2 fee

>$2 fee No fee

ATM Locations & Features:

Results by Bank

Bank _{of ATMS} Number Distrib-Geog. ution Multi-lingual Function Non-cust. Fee Non-bank ATM Fee Mean 3.5 2.2 N/A $2.90 $1.89 Bank of America 8 6 Multiple $3.00 $2.00 Bank of

Southern CT 4 4 Eng. only $2.00 $3.00

Citibank 2 1 Multiple $2.00 No fee

First Niagara 5 2 Eng. + _Span. $4.00 $2.00 JPMorgan

Chase 2 2 Multiple $3.00 $2.00

People’s

United 2 1 Eng. + Span. $3.00 No fee

RBS Citizens 4 2 Eng. + _Span. $4.00 $3.00 Sovereign

Bank 4 2 Eng. + Span. $3.00 $3.00

TD Bank 2 0 Multiple $3.00 $2.00

Webster Bank 3 3 Multiple $3.00 $2.00 Wells Fargo

Bank 3 1 Multiple $3.00 $3.00

2 points

1 point

3 points

ATM Locations & Features:

Points Allocated

Fee structure: Each bank was assessed on whether it offered a

no-fee account with no strings attached, i.e., no monthly

minimum balance requirement.

Minimum opening balance: Required initial deposit in order to

open a savings account.

Minimum no-fee balance: In addition to variations in the

monthly maintenance fees charged by banks (see above),

banks can vary in the balance they require a consumer to

maintain before waiving the fee. Additionally, not all banks

calculate that minimum balance in the same way: they typically

either charge a fee if the account dips below the minimum

balance at any point in the month, or only charge if the average

value of the account during the monthly statement period drops

below the respective minimum balance requirements.

<$4.50 monthly charge

$4.50+ charge No-fee account

$11-50

>$50 $10 or less

$250-500 avg/$100-300 min

>$500 avg/$300 min <$250 avg/$100 min

ATM Locations & Features:

Results by Bank

Bank Fee structure Min opening _balance Min no-fee _balance

Mean $4.68 $54.09 N/A

Bank of America $5.00 $25.00 $300 Min Bank of Southern CT $3.00 $5.00 $1000 Average

Citibank $10.00 $100.00 $1500 Average

First Niagara $4.00 $50.00 $200 Min

JPMorgan Chase $4.00 $25.00 $300 Min

People’s United $5.00 $250.00 $250 Min

RBS Citizens $4.99 $25.00 $300 Min

Sovereign Bank $3.50 $10.00 $100 Min

TD Bank $4.00 None $250 Min

Webster Bank $3.00 $5.00 $300 Min

Wells Fargo Bank $5.00 $100.00 $300 Min

2 points

1 point

3 points

ATM Locations & Features:

Points Allocated

Fee structure: As with savings accounts, each bank was

assessed on whether it offered a no-fee account with no strings

attached, i.e., no monthly minimum balance requirement.

Minimum opening balance: Required initial deposit in order to

open a checking account.

Minimum no-fee balance: See discussion of minimum no-fee

balance variations by banks in Category C.

Overdraft penalties: Banks were also assessed on the penalty

charged for customer overdrafts. Since some banks reduce the

charge for subsequent overdrafts in a defined period, banks’

scores were calculated based on the average of the first five

overdrafts.

<$4.50 monthly charge

$4.50+ charge No-fee account

$26-50

>$50 $25 or less

$750+ avg/$500+ min

>$750 avg/$500 min No min reqs

D. Personal Checking Accounts Points Allocated

$26-35

ATM Locations & Features:

Results by Bank

Bank _structure Fee opening Min balance

Min no-fee

balance Overdraft penalties

Mean $8.68 $38.64 N/A $32.64

Bank of America $12.00 $25.00 $1500 Min $35.00 Bank of

Southern CT $7.00 $100.00 $2000 Avg $31.00 Citibank $10.00 None $1500 Avg $34.00 First Niagara $7.50 $50.00 $300 Min $35.00 JPMorgan Chase $12.00 $25.00 $1500 Min $34.00 People’s United $10.00 None $750 Min $36.00 RBS Citizens $9.99 $50.00 $1500 Min $11.99 Sovereign Bank $5.00 $25.00 $500 Min $35.00

TD Bank $3.99 None None $35.00

Webster Bank $8.95 $50.00 $1000 Avg $37.00 Wells Fargo Bank $9.00 $100.00 $1500 Min $35.00

2 points

1 point

3 points

ATM Locations & Features:

Points Allocated

Fee structure: As with savings and checking accounts, each

bank was assessed on whether it offered a no-fee small

business account with no strings attached, i.e., no monthly

minimum balance requirement. For every metric within the

Small Business Account category, data was collected for each

banks’ most basic small business offerings, typically those

designed for truly small, local businesses.

Minimum opening balance: Required initial deposit in order to

open a checking account.

Usage criteria: Reflecting the intended scale of these types of

small business accounts, banks often set limits on the number

of transactions permitted per month before charging fees

(typically <$1.00 per additional transaction).

$10+ charge No-fee account

$26-100

>$100 $25 or less

250-400 transactions

<250 transactions 400+ or no limit

ATM Locations & Features:

Results by Bank

Bank Fee structure Min opening _{balance criteria} Usage

Mean $12.02 $97.73 212.5

Bank of America $15.00 $100.00 400

Bank of Southern CT $10.00 $100.00 No limit

Citibank $13.25 $100.00 200

First Niagara No fee None 75

JPMorgan Chase $15.00 $25.00 200

People’s United No fee None 300

RBS Citizens $9.99 $100.00 200

Sovereign Bank $15.00 $25.00 300

TD Bank $8.00 $25.00 200

Webster Bank $9.95 $500.00 100

Wells Fargo Bank $12.00 $100.00 150

2 points

1 point

3 points

ATM Locations & Features:

Points Allocated

Account opening criteria: The City of New Haven introduced the

Elm City Resident Card in 2007 with the goal of increasing

access to services for many residents, including banking. Banks

were asked whether they accepted the card, or other alternative

forms of identification, as the primary ID required to open an

account, as a secondary form (used in addition to a primary

form), or not at all.

Personal loans: Banks were judged on the breadth of personal

loan offerings, including auto/RV, boat, and other loans.

Check cashing: Although consumers should generally be

encouraged to open savings accounts and not rely on ad hoc

check cashing, there are circumstances that preclude

individuals from doing so in some cases. Banks were asked

whether they would cash checks for non-customers, for a fee or

for free, and dependent on whether the check was issued by

the bank itself. Banks that did not have a clear, consistent

policy received 1 point.

Alternative products: Since New Haven is a college town, with

Yale University, the University of New Haven, Southern

Connecticut State University and Albertus Magnus College all

within its borders, it is sensible for banks operating in the city

to offer specialized student accounts. Banks can also offer

second-chance accounts, targeted to individuals with low credit

scores, club savings, holiday accounts, and senior or minor

savings accounts.

Secondary ID

Did not accept Primary ID

Charged $5+

Would not cash <$5 or no fee

F. Other Points Allocated

Student only

No alternatives Multiple alternatives

ATM Locations & Features:

Results by Bank

Bank Account _opening Personal _{loans cashing} Check Alterna-tive products

Mean N/A N/A N/A N/A

Bank of America Secondary Yes No fee Multiple Bank of

Southern CT No No No fee No

Citibank Secondary Yes No Student only

First Niagara No Yes No fee No

JPMorgan Chase Yes Yes Fee Student only

People’s United No Yes No Student only

RBS Citizens No Yes Fee Multiple

Sovereign Bank Secondary Yes No fee Student only

TD Bank No Yes Fee Multiple

Webster Bank No Yes No Multiple

Wells Fargo Bank Secondary Yes No fee Student only

2 points

1 point

3 points

Bank Report Cards

Bank

Score (Out of 100)

First Niagara Bank

74

Bank of America

73

People's United Bank

68

JPMorgan Chase Bank

66

Bank of Southern CT

63

Webster Bank

61

RBS Citizens

59

TD Bank

59

Citibank

56

Sovereign Bank New England

56

Wells Fargo Bank

53

First Niagara

Total score: 74/100

• Home Loans: 26/30

• Banking Products & Accessibility: 48/70

Strengths

Areas for Improvement

highest point total on Home Loans category

• Second highest number of bank branches and ATMs in New Haven

• Non-customers are not charged a fee for cashing a First Niagara check at the bank • Offers no-fee small business

accounts with no minimum balance

• No branch is open after 6 PM • Highest fees charged for

non-bank customers to use non-bank ATMs ($3.50)

• Does not accept Elm City

Resident Card to open account • Small business account offers

only 75 free transactions per month, lowest limit among

banks studied

• One of only two banks in New Haven that does not offer alternative products, including student accounts

Bank of America

Total score: 73/100

• Home Loans: 22/30

• Banking Products & Accessibility: 51/70

Strengths

Areas for Improvement

Banking Products & Accessibility category

• Most branches in New Haven, including the most in

Empowerment Zones • Most ATMs in the City,

including the most in

Empowerment Zones, and ATMs offer services in multiple languages

• Offers a wide array of personal loan options

• Does not charge a fee for non-customers to cash checks written on Bank of America checks

• High number of transactions allowed for small business accounts without fees

• Offers multiple alternative accounts

• No branch is open after 6 PM • Checking account monthly

fee is highest in City ($12) • Small business account

monthly fee is highest in City ($15)

People’s United Bank

Total score: 68/100

• Home Loans: 24/30

• Banking Products & Accessibility: 44/70

Strengths

Areas for Improvement

Saturdays and evening hours • Does not charge customers a

fee to use non-bank ATMs • No minimum balance

requirements to open a checking account

• Offers no-fee small business accounts with no minimum balance

• Highest minimum balance to open a personal savings

account in New Haven ($250) • Does not accept Elm City

Resident Card to open account • Charges one of the highest

overdraft penalties ($36) • Will not cash checks for

JPMorgan Chase Bank

Total score: 66/100

• Home Loans: 20/30

• Banking Products & Accessibility: 46/70

Strengths

Areas for Improvement

loan applications by Latinos and Blacks in the City of New Haven, and among the

highest acceptance rates overall

• ATMs offer services in multiple languages

• Accepts Elm City Resident Card to open an account

• Checking account monthly fee is highest in City ($12) • Small business account

monthly fee is highest in City ($15)

Bank of Southern CT

Total score: 63/100

• Home Loans: 22/30

• Banking Products & Accessibility: 41/70

Strengths

Areas for Improvement

made in the City of New Haven vs. New Haven County, and highest

percentage of loans made in the City vs. nationally

• Lowest monthly

maintenance charge ($3) for savings accounts of New Haven banks

• Requires low minimum open balance for savings accounts ($5)

• Only bank in New Haven to allow unlimited free

transactions for small business accounts

• Reported no Latino or Black applicants for home loans • Does not offer staff members

who speak languages other than English

• ATM services are only offered in English

• Does not accept Elm City

Resident Card to open account • One of only two banks in New

Haven to require $100 opening deposit for a checking account • Highest balance requirement

($2000) to avoid monthly

maintenance fees for a checking account

• Only bank studied not to offer an array of personal loans • One of only two banks in New

Haven that does not offer alternative products, including student accounts

Webster Bank

Total score: 61/100

• Home Loans: 16/30

• Banking Products & Accessibility: 45/70

Strengths

Areas for Improvement

spoke several languages other than English, including Portuguese, Spanish and Polish • ATMs offer services in multiple

languages

• Offers multiple alternative accounts, such as a holiday club and Opportunity Checking account

• Lowest percentage of loans accepted in New Haven City vs. County (3.4%)

• Does not accept Elm City

Resident Card to open account • Charges the highest overdraft

penalties ($37) in the City of New Haven

• Highest minimum balance to open a small business account ($500)

• No consistent policy regarding check-cashing for

RBS Citizens

Total score: 59/100

• Home Loans: 16/30

• Banking Products & Accessibility: 43/70

Strengths

Areas for Improvement

first overdraft for 13 business days (from $37 to $6.99)

• Offers breadth of alternative accounts, including College Saver accounts, HomeBuyer Savings , Steady Save program, and Student Checking (Student Money Bundle)

• Did not accept a single Black loan applicant in 2010 (out of 6 applicants); accepted only one Latino applicant (out of 5) • Does not accept Elm City

Resident Card to open account • One of the highest balance

requirement ($1500) to avoid monthly maintenance fees for a checking account

TD Bank

Total score: 59/100

• Home Loans: 10/30

• Banking Products & Accessibility: 49/70

Strengths

Areas for Improvement

Saturdays and evening hours • ATMs offer services in multiple

languages

• Only bank studied that did not have a minimum balance requirement to open a personal savings account • No minimum balance

requirements to open a checking account, and no on-going minimum no-fee balance requirement

• Offers breadth of alternative accounts, including Student accounts, 60+accounts, Young Saver, Club Saver, and Holiday Club

• Lowest loan acceptance ratio overall in the City of New Haven • Did not accept a single

Latino loan applicant in 2010 (out of 8 applicants); accepted only four Black applicants (out of 20)

• Lowest percentage of home loans made to low income individuals (31%)

• No branches or ATMs located in Empowerment Zones

• Does not accept Elm City

Citibank

Total score: 56/100

• Home Loans: 16/30

• Banking Products & Accessibility: 40/70

Strengths

Areas for Improvement

made to applicants below county average income (85.4%)

• Employed staff members who spoke several languages other than English

• ATMs offer services in multiple languages

• Does not charge customer a fee for using non-affiliated ATMs • No minimum balance required

to open a personal checking account

• Second to lowest in percentage of loans accepted in New

Haven (39.3%)

• Charges the highest monthly fee ($10) among New Haven banks for personal savings accounts, coupled with the

highest balance requirement ($1,500) to avoid monthly

maintenance fees

• One of the highest minimum balance to open a personal savings account in New Haven ($100)

• Will not cash checks for non-account holders, even for

Sovereign Bank New England

Total score: 56/100

• Home Loans: 8/30

• Banking Products & Accessibility: 48/70

Strengths

Areas for Improvement

non-customers to cash checks written on bank

• Lowest point total on Home Loans category

• Did not accept a single

Latino loan applicant (out of 2 applicants); accepted only one Black applicant (out of 4)

• Small business account monthly fee is highest in City ($15)

Wells Fargo Bank

Total score: 53/100

• Home Loans: 14/30

• Banking Products & Accessibility: 39/70

Strengths

Areas for Improvement

languages

• Does not charge a fee for non-customers to cash checks written on bank

• Lowest score overall and

lowest point total in Banking Products & Accessibility

category

• Only one of banks studied not to offer free online bill pay (costs $3/month)

• One of the highest minimum balance to open a personal savings account in New Haven ($100)

• One of only two banks in New Haven to require $100 opening deposit for a checking account • One of the highest balance

requirement ($1500) to avoid monthly maintenance fees for a checking account