Finance, Banking, Litigation


The U.S. financial system faces a crisis. Unlike fiscal crises, this one is of consumer confidence and trust. Recent polls suggest that faith in American banks is at a forty-year low. Many blame the banking sector for having a significant role in causing and exacerbating the financial crisis of 2008, as well as the deep recession that has followed. Scandals, litigation, and a lack of accountability for conduct that has breached the public trust mean that many consumers of bank services are starting to call for greater transparency in banking practices, financial institutions that are more responsive to community needs, and a broader array of alternatives to traditional banks. Initiatives such as the Move Your Money campaign and Bank Transfer Day have captured the imagination of many bank customers who are looking to use their consumer clout to support financial institutions that are engaged in responsible practices. Perhaps as a way to counter this crisis in confidence, regulators, local governments and consumers alike seek ways to measure bank responsiveness to consumer wishes and community needs. This paper describes one such tool: the Community Impact Report Card (“CIRC”). Modeled on other grading systems—such as New York City’s method for grading restaurants—and informed by principles of behavioral economics, CIRC is a tool designed to offer consumers a means through which they can easily comparison shop between banks. This comparison is based on those banks’ effectiveness in meeting consumer demand for accessible and inexpensive products and services, and is also meant to encourage banks to strengthen the array of products and services they offer. By providing a range of information about the products and services offered by local banks, and generating a single score for each bank based on this information on a scale of 1–100, consumers will have an easily accessible way to compare how each bank serving the community is generally responsive to local needs and interests. Flexible and adaptable, CIRC system is designed to be tailored to the needs of local communities and to be applied to the array of financial institutions that serve them.



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