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Access Denied The Failure of Voluntary Measures to Improve Banking Services 1999 National Survey Report (June 1999)

                          Acknowledgements

The CCRC would like to thank all the individuals who helped conduct the survey in this report through the following groups:


          Victoria          The Vancouver Island Public Interest Research Group


          Yellowknife       Alternatives North


          Edmonton          Edmonton Social Planning Council


            Winnipeg          Social Planning Council of Winnipeg

                                        Winnipeg Harvest


             Regina             Regina Anti-Poverty Ministry


             Saskatoon          Equal Justice for All


             Toronto            Centre for Equality Rights in Accommodation (CERA)

                                         LIFT (Low Income Families Together)


             Ottawa             Democracy Watch National

                                         Anti-Poverty Organization


              London           LIFE*SPIN


              Montreal          The Magical Filipina Inc.


              St. John's          Group Against Poverty

"close to one in five Canadians reported facing a holding period before being able to access funds placed in their account, and as many as 8 percent reported holds on cheques issued by governments. Among young people and lower-income groups, 15 percent reported experiencing holds on government cheques."

 The Task Force stated that there was no legitimate reason for a hold period on government cheques, especially since an indemnification program exists that protects banks against fraud. Waiting periods can last six to 10 days, despite the fact that the Canadian payments system clears almost all transactions overnight, or at most, within three days.

 Because they generally have little or no savings, those in a low-income bracket often cannot afford the cash crunch that results from these hold periods. As a result, low-income Canadians increasingly rely on cheque-cashing firms such as Money Mart, which opened in 1983 with 16 outlets and today has more than 175 (up from just over 130 in 1997).

 Another factor discouraging low-income Canadians from opening accounts is user fees. The continued refusal by financial institutions to disclose cost data makes it impossible to determine whether consumers are being gouged or whether bank service charges reflect a fair return for financial institutions. Some argue that financial institutions should not be forced to do anything that is not profitable. However, the MacKay Task Force concluded that Canadians expect that banks should undertake "activities that may or may not be profitable." These expectations, the Task Force concluded, result from the many privileges and protections banks have received in the past, but the Task Force stated that these expectations should also apply to other financial institutions (pp. 148-149).

 What might be considered the ultimate access barrier is when a bank branch closes. These closures often occur in disadvantaged neighbourhoods. Among many others across Canada, Pointe St.-Charles in Montreal, the Regent Park area of Toronto, and the Downtown Eastside area of Vancouver have all experienced significant branch closures in recent years.


(c) Government Action to Date: Inadequate to Ensure Access to Basic Banking Services

 Concerns about access to basic financial services led the Canadian Community Reinvestment Coalition (CCRC) and others to call on the federal government to require banks to lower these barriers and serve all Canadians fairly. To stave off such regulation, the banks promised the federal government in a behind-closed-door agreement in early 1997 that they would remove these barriers voluntarily. The agreement, announced in February 1997, stated that the banks would:

• only require, at most, two pieces of identification to open a bank account or cash a cheque, and not require photo identification;
• no longer require people to have a job in order to open a bank account;
• no longer require a minimum deposit to open an account;
• provide customers with greater information about the holding of deposited funds;
• train staff to follow these policies and be more sensitive to low-income Canadians; and
• provide information to low-income groups on how to be more knowledgeable and comfortable using banking services.

 However, the emptiness of the bank's promises, and the ineffectiveness of voluntary guidelines, was soon revealed.

 In October 1997, the CCRC conducted an informal survey on access to basic financial services. It showed that five of the Big Six banks violated the February 1997 agreement. Banks were requiring more than two pieces of identification, photo ID, minimum balances and Credit Bureau checks, all of which can easily be used as a barrier to access. The National Bank was the only member of the Big Six that was not found to be violating the 1997 agreement.

 Amazingly, even in an ACNielsen Canada study commissioned by the Canadian Bankers Association and released in August 1998, shoppers posing as low-income Canadians were unable to open accounts when they produced only two pieces of identification (a driver's license and a social insurance card). Banks demanded a minimum deposit or a third piece of identification in 41% of the cases.

 In addition to successfully delaying government regulation in this area, the voluntary code negotiated with the government continues to benefit the banks by allowing them to boast that they have taken steps to making banking more accessible. As recently as May 1999, promotional material by the Canadian Bankers Association touted the 1997 promises of "more flexible cheque-cashing and account-opening requirements," as well as an initiative of giving bank staff "sensitivity training to help them better meet the needs of low-income Canadians."

 
City by city, financial institutions are also failing to meet their promises. The following is a summary of the results broken down by city moving from west to east across Canada (complete branch-by-branch results for each city are set out in Appendix I):


Victoria, B.C. (8 surveys)
 Five branches out of eight are not in compliance with the code on requirements for opening accounts. None are in compliance with the code on cashing-cheques.

Yellowknife, N.W.T. (2 surveys)
 One bank is not in compliance with the code on both opening accounts and cashing cheques. The other bank surveyed says that photo ID is only "preferred" when opening a new account, although their account application form asks for SIN number and employment information.

Edmonton, AB (10 surveys)
 Eight out of 10 financial institutions are not in compliance with the code on both opening accounts and cashing cheques. Two additional financial institutions comply with the code on opening accounts, but not on cashing cheques. Two financial institutions demand a credit check on opening a new account.

Saskatoon, SK (8 surveys)
 Five financial institutions out of eight are not in compliance with the code on ID required for opening new accounts. None comply with the code on cheque-cashing requirements. Surveyors were unable to gather information from one bank, as they were told they had to wait an hour before they could speak to someone about opening an account. No information was provided at this branch; the surveyors were brushed off and turned away quickly.

Regina, SK (7 surveys)
 None of the financial institutions were in clear compliance with the code on both opening accounts and cashing cheques. While all complied with the code on ID requirements for new accounts, seven out of seven would cash only government cheques, or cheques drawn on accounts at the branch, while requiring only two pieces of ID. One institution charges a $3.00 cheque-cashing fee.

Winnipeg, MB (16 surveys)
 None of the financial institutions were in clear compliance with the code on both opening accounts and cashing cheques. Thirteen out of 16 (83%) are not complying with the code on ID requirements for opening accounts. For cashing cheques, only one is clearly in compliance with the code. One other bank would comply when cashing government cheques only, and another would cash government cheques, but only up to $1,200.

London, ON (9 surveys)
 Seven out of nine financial institutions are not complying with the code on ID requirements for opening accounts, but of the other two institutions, one requires that the two pieces of ID be issued by government or a financial institution, while the other said that "usually," one piece of ID must be photo. None are in compliance with the code on cheque-cashing requirements, although one would cash a government cheque or a cheque drawn on the branch, and would require only two pieces of ID.

Toronto, ON (8 surveys)
 Six out of eight financial institutions are not in compliance with the code on ID requirements for opening accounts. None of the banks comply with the code on ID requirements for cheque-cashing.

Ottawa, ON (19 surveys)
 Sixteen out of 19 financial institutions are not in compliance with the code on requirements for opening accounts, and at one of the three in compliance the staff person repeatedly mentioned photo ID as examples of what sort of ID was acceptable. None were in compliance with the code on cheque-cashing requirements.

Montreal, Qc (8 surveys)
 Montreal financial institutions had the worst record of any city. None of the banks surveyed comply with the measure in the code that requires only two pieces of ID with no photo ID to open an account. Seven out of nine institutions require a lease to open an account. All require an account to cash a cheque.

St. John's, NF (8 surveys)
 Five out of eight financial institutions are not complying with the code on ID requirements for opening an account. Six out of eight are not complying with the code on cheque-cashing requirements. Only two institutions were in compliance with the code both on requirements to open an account and to cash a cheque. One specifically requires a driver's license and SIN card.


 Some of the specific responses given to surveyors by bank staff are especially disturbing. At least five branches demanded credit checks before opening new accounts. Nine branches demanded a lease, while others required that applicants Òlive nearby,Ó a particularly troubling requirement, given the number of branches that have closed in low-income neighbourhoods across Canada. At least six branches require that applicants for accounts be employed. At one Ottawa branch, the surveyor was told flat out that the branch would not open an account if she was unemployed. "We only deal with professionals," the staff person said, adding that "any other branch will take you."

 Hold periods were also quite common, some as high as 30 days, despite most cheques clearing the Canadian Payments Association within three days. Even federal government cheques, indemnified against fraud by the government, were frequently subject to hold periods of three to six days.

 In Ottawa, five of the institutions surveyed had also been surveyed in October 1997 by the CCRC to see if they were honouring the opening accounts promise. Four of the five did not comply with the code on requirements to open accounts. In the 1997 survey, only one institution complied with the code. In 1999, that institution was no longer in compliance (see Appendix I for details).

"is that not all direct marketers belong to the association, and there is no mechanism for ensuring that they abide by the same rules. Not all business or industry associations have undertaken voluntary measures, and there may be a short-term incentive for some companies to ignore such measures and to use personal information inappropriately. This can undermine fair competition in the marketplace, creating an unlevel playing field. It can also erode consumer confidence in an entire industry and create further confusion about rights and rules."

The 1997 agreement on access to banking services operates in quite similar conditions and suffers from identical problems.

 Voluntary Codes: A Guide for Their Development and Use, a joint 1998 publication of the Office of Consumer Affairs at Industry Canada and the Treasury Board's Regulatory Affairs Division, notes that an effective code "should include some combination of self-reporting obligations for adherents, powers of monitoring, compliance verification or auditing, impact assessments and the ability to publicize data on compliance and non-compliance." The publication, which surveyed a wide range of voluntary industry measures, advocates that community and non-governmental organization (NGO) representatives be involved in code development and compliance verification.

 Both the Voluntary Codes publication, and the Electronic Commerce Task Force report also recognize the clear necessity for strong penalties for non-compliance with any industry code. According to Voluntary Codes, enforcement must be through a body that is accountable to the public, with an appeal mechanism for unsatisfied customers and a periodic review and updating of the code, involving consumer, government and industry representatives. Taken together, these conditions amount to the conditions for effective legislation or regulation of any area of business activity. However, as noted above, legislation and regulations apply to all businesses in a sector, and are thereby clearly much more effective than voluntary codes at protecting consumers.

 Despite claims to the contrary by the federal government and financial institutions, the 1997 guidelines on access to basic banking services do not meet any of the essential criteria set out above for an effective industry code. Not surprisingly, this has resulted in an almost total lack of compliance by financial institutions.

 In September 1998, the MacKay Task Force, faced with evidence (including their own small survey) that the banks were not complying with the 1997 code on access to basic banking services, argued in its report that the problem was "attitudinal." It recommended a variety of measures which fell short of requiring financial institutions to comply with their promises. The Task Force concluded, however, that legislation and strong penalties will be necessary if institutions do not change their behaviour:

"We are hopeful that these actions will increase access and we would expect progress within a reasonable period of time. If progress is not being made, we recommend that the government legislate the terms of the February and December 1997 agreements, with appropriate sanctions for non-compliance."

 In December 1998, the Senate Committee on Banking, Trade and Commerce, and the House of Commons Standing Committee on Finance both released reports reviewing and responding to the MacKay Task Force report. The committees agreed with the MacKay Task Force that legislation should be enacted to guarantee access to banking services if financial institutions do not change their behaviour. In addition, the committees agreed with the Task Force that legislation is needed: to ensure full disclosure and transparency on contracts for financial products and services; to ensure personal information is protected; to prohibit tied selling; to ensure full and proper notice of branch closures; to ensure full disclosure of business lending patterns and practices; to require professional standards for financial planners; and to review the service record of financial institutions and future impacts when considering any merger or takeover proposals.
 Through their endorsement of the Task Force's recommendations proposing comprehensive legislation to protect financial consumers and hold financial institutions accountable for poor service, the committees have made it clear that they agree that voluntary codes are ineffective.

Recommendation 1: Government should not use voluntary codes to regulate the financial services industry in any area. If any government proposes voluntary measures to regulate the industry, it will show clearly that government does not care at all about protecting consumers or holding financial institutions accountable for poor service.

 Given that financial institutions have failed to make any progress in terms of providing access to banking services fairly to all Canadians since the September 1998 MacKay Task Force report, and their performance in this area has even worsened, the time for legislated guarantees on access is clearly at hand.

 In other jurisdictions, the right of access to basic banking services has been enshrined in law. In France, for example, if a French resident can prove that two banks have rejected him or her as a client, the Banque de France will select a bank which is then mandated to accept the new client. In the United States, many states -- including Illinois, Massachusetts, Minnesota, New Jersey and New York -- require banks to offer minimum services to the population at large.

 In New York State, a maximum monthly fee of $3.00 (US) for a no-frills account allowing eight withdrawals per month ensures that opening an account is affordable.

Recommendation 2: All persons able to prove that they are residing in Canada, upon proof of status, should be guaranteed an account with a financial institution and this right ought to be entrenched in the Bank Act, the Trust Companies Act and other deposit-taking institutions' legislation (See the CCRC's Position Paper #2, Access to Basic Banking Service: Ensuring a Right to This Essential Service, for details concerning this recommendation and recommendations 3 to 10 below).

Recommendation 3: All consumers should be entitled to a low-cost account option that will satisfy their basic needs and will not entail paying excessive service charges above the basic cost. This basic account should allow, each month, for payment by cheque of all utility bills and a rent or mortgage payment, and a weekly cash withdrawal, all at a fixed monthly fee. If financial institutions refuse to provide a detailed analysis of their service transaction costs and revenues so that a justifiable monthly fee for such an account can be determined, the federal government should determine a justifiable maximum monthly fee for such an account after consultation with people with low incomes and citizen groups, and enact in law the fee and the right to open such an account for all bank customers. In addition, a periodic review of the services provided and cost of this account should be conducted to ensure that the services and fee continue to match the reality of the provision of bank services and costs.

 With regard to the practice of requesting credit checks when opening an account, the banks argue that credit checks help ensure the creditworthiness of potential clients. However, if a customer does not need or want access to an automatic teller machine (ATM) card when opening an account, every transaction for that customer will be reviewed by an employee of the financial institution. As a result, each employee can ensure that the institution's risks are covered in terms of how each transaction is handled.

 In any event, a credit check should not act as a barrier even for those wishing to use automatic banking machines. For customers using automatic banking machines, the only risk to the financial institution that the account holder can cause is if the he or she deposits a bad cheque or an empty envelope into their account through the machine, and then withdraws the fraudulently deposited amount. To eliminate this risk, financial institutions can simply place a hold on all funds deposited by customers with poor credit ratings until the funds clear the system.

Recommendation 4: Financial institutions should be prohibited by law from requiring authorization to conduct a credit check from potential customers who do not need or want access to an automatic banking card when opening an account, because there are ways that financial institutions can minimize their risk of losses with regard to all of the services they provide to such customers. Financial institutions should be allowed to require authorization to conduct a credit check from potential customers who want to use automatic banking services as a condition of opening an account. However, financial institutions should be prohibited by law from using a poor credit rating as a reason to refuse to open an account for anyone. In the case of a person with a bad credit history, financial institutions should be allowed to hold deposited funds until they are cleared in order to minimize the institution's risk. In almost all cases, this clearance process will take three days or less, and this time period should guide the setting of limits on the holding time for cheques and other deposits.

 Excessive hold periods on all deposited funds should also be eliminated. In the United States, the Expedited Funds Availability Act (EFAA) governs the time period for which deposits may be withheld from a customer. For in-branch deposits or inter-bank fund transfers, the EFAA requires that funds be made available to the depositor by the beginning of the first business day following the deposit. This same time frame applies to U.S. government cheques endorsed by their payee. In addition, $100 on the value of any cheque deposited must be made available to the customer on the first business day following the day that the deposit is accepted (except in specific circumstances, such as large cheques and with accounts that have been overdrawn repeatedly).

 Canadian Payments Association (CPA) standards make it highly unlikely that a cheque will take more than three days to clear when it is posted from one Canadian financial institution and deposited in an account at another Canadian financial institution. As a result, even in the case of an individual with a bad credit rating, a financial institution could still release any funds deposited in less than the six to 10 days (or even higher, in some banks surveyed) that many financial institutions currently hold deposited amounts.

 Hold periods of any kind on government cheques are also completely unjustified, given that the government indemnifies banks against fraud.

Recommendation 5: The federal government, consumer representatives, financial institutions and the Canadian Payments Association should jointly develop attainable standards regarding the crediting of cheques, including government cheques, to a depositor's account. Once these have been established, legislated provisions similar to those found in the U.S. Expedited Funds Availability Act (EFAA) should be enacted by Parliament. This legislation should apply for all consumers, and should ensure that arbitrary, excessive holding of cheques is prohibited and that penalties for violating the legislative requirements are sufficient to discourage the practice.

 Cashing cheques, especially for low-income individuals, is an essential service. Yet the banks are in clear violation of their promise to require only two pieces of identification, with no photo ID requirement. This should be remedied with government legislation.

Recommendation 6: The federal government should prohibit financial institutions from requiring more than two pieces of identification, or requiring photo ID, in order to cash a cheque.

 One of the promises made by financial institutions in the February 1997 agreement was to educate their customers with regard to their rights. Given that the institutions are still turning away potential customers in violation of the agreement, it is clear that the institutions are doing little to educate customers about the new access rules. As a result, financial institutions should be required to post the rights of customers with regard to opening new accounts and cashing cheques.

Recommendation 7: Banks should be required to post prominently, in every branch, a notice setting out the rights of customers with regard to opening new accounts and cashing cheques.

 As financial institutions' poor performance with regard to the February 1997 agreement on access to banking services shows, these recommendations will have little effect without adequate monitoring and enforcement.

Recommendation 8: The federal government, consumer representatives and financial institutions should develop a periodic, random and effective monitoring system (such as an unannounced, anonymous survey of a representative sample of financial institutions) to ensure that financial institutions comply with the legislative requirements concerning access to basic financial services for all Canadians, and should develop penalties sufficient to ensure compliance.

 The government should also consider measures to minimize that harm caused by bank closures, which completely withdraw access to banking services for the affected community. First, the public should have a right to assess claims by financial institutions that the neighbourhoods they pull out of are genuinely unprofitable.

Recommendation 9: To allow for a public assessment of the withdrawal of banking services from a community or neighbourhood, deposit-taking financial institutions should be required to disclose a branch's profit/loss record and net income prior to closing the branch.

 Second, the government should consider giving direct subsidies to communities suffering from a lack of financial services. This could include direct subsidies to establish branches to serve less profitable areas. For example, establishing a credit union with a board of directors elected by and from amongst members of the community. The credit union structure helps ensure accountability to the community and also involves members of the community in the management of the capital that the community generates, facilitating long-term community development.

Recommendation 10: In areas of Canada where there are few or no financial institutions, governments should consider providing incentives or even direct subsidies to existing financial institutions to establish special branches to serve these areas. If no financial institution will establish a special branch in a particular area, governments should consider providing subsidies for the establishment of a financial institution to provide basic banking services, in consultation with the community.

 To fully address the problems many financial consumers face, the federal government must address the issue of balancing the marketplace. Consumers are spread across the country and currently face high barriers to banding together to hold financial institutions accountable for poor service, while financial institutions can easily collect millions of dollars from consumers through overcharging for services and use those funds for extensive advertising and lobbying campaigns, defending lawsuits, or influencing politicians with donations.

 Consumers need a permanent, well-resourced organization to counter the power of financial institutions in the marketplace by receiving and helping resolve complaints, ensuring that financial institutions comply with laws, and representing consumers in regulatory and policy-making processes. The CCRC's proposal to create a Financial Consumer Organization (FCO) in Canada would fulfill this role very effectively, at little or no cost to government and financial institutions.

Recommendation 11: Federally regulated bank, trust and life and health insurance companies should facilitate the start up of a Financial Consumer Organization (FCO) by enclosing the FCO's flyer in their mailing envelopes sent to their customers. If they do not do so voluntarily, the federal government should legislate the FCO's right to enclose its information and solicitation flyers periodically in mailouts that federally regulated bank, trust and life and health insurance companies already send to their customers (See the CCRC's Position Paper #4, A Financial Consumer Organization for Canada: Balancing the Financial Services Marketplace, for details).

 While an FCO would, among other activities, effectively help consumer file complaints about poor service, an independent enforcement agency is needed to review and rule on complaints. As detailed in the CCRC's first Position Paper, Bank Ombudsmen: Why They Must Be Independent, the current bank-appointed ombudsmen have failed to make banks accountable for poor service of their customers.

Recommendation 12: An independent ombudsman for the financial services industry should be established by the federal government, with funding required from federally regulated financial institutions and with the power to make binding rulings, as part of the overall financial institution accountability system in Canada (See the CCRC's Position Paper #1, Bank Ombudsmen: Why They Must Be Independent, for details).

 As set out in the above recommendations, increasing the rights of financial consumers and the responsibilities of financial institutions, and ensuring that consumers have a consumer-directed organization to call for help and an independent agency to review complaints and enforce rulings will help greatly in protecting consumers and holding financial institutions accountable for poor service.

 However, changes are ongoing in the financial services industry, including mergers and takeovers, and Canadian governments lack any systematic tracking and review process to ensure that changes are in the public interest. The U.S. has had a fairly effective system for this purpose for over 20 years, and it is essential that Canada adopt a similar system.

Recommendation 13: A financial institution accountability system including detailed disclosure of the lending, investment and service record of financial institutions in each community, a government review of this record, and significant and appropriate penalties for a poor record, should be enacted in Canada. The Canadian system should be based upon the U.S. system which has worked effectively for over 20 years (For details, see the CCRC's Position Paper # 3, Disclosure By Banks Of Business Lending Statistics: How to Correct the Flaws in the Current System; Position Paper #5, An Accountability System For Canada's Financial Institutions: How To Ensure They Meet a High Standard of Performance; Position Paper #6, Ending Power Without Accountability: Making Banks in Canada Better Before They Get Bigger; and report Bank Rhetoric or Customer Reality: Key Questions About the Competition Bureau's Analysis of the Proposed Bank Mergers (November 1998)).

 Finally, governments must ensure that foreign financial institutions and currently unregulated financial institutions are not permitted to escape the consumer protection and accountability system set out in the above recommendations, especially since the federal government has recently lowered barriers to the entry of foreign financial institutions into the Canadian market.

Recommendation 14: In order to ensure that all financial institutions operating in Canada comply with the recommended legislative measures set out above, governments should enact specific measures to ensure that foreign banks and currently unregulated financial institutions comply with the measures.

Key:
1) Answer to question: What is required to open an account?
2) Answer to question: Can you cash a cheque if you do not have an account?
3) Answer to question: What is required to cash a cheque?

Bank of Montreal, 1225 Douglas St.
1) Two pieces of ID, including one photo, or three pieces secondary ID
2) No
3) Active account; hold period at first until cheque clears

Canada Trust, 1125 Douglas St.
1) Two pieces of ID, one photo, both signature
2) No
3) Only government cheques

Canadian Western Bank, 1201 Douglas St.
1) Two pieces of ID, including one government-issued photo ID -- no exceptions
2) No
3) Active account in good standing

CIBC, 1175 Douglas St.
1) Two pieces of ID, one photo ID (government)
2) Only if cheque is from this branch
3) Active account

Hongkong Bank of Canada, 752 Fort
1) Two pieces of ID, prefer photo for both, or photo and credit card
2) No
3) Only drawn on our branch, two pieces of ID

Royal Bank, 1079 Douglas St.
1) Two pieces of ID, valid and with signature
2) From this branch only
3) Cheque from this branch only; Two pieces of ID

Scotiabank, 702 Yates St.
1) Two pieces of ID
2) No, unless from this branch
3) Active account -- to cash personal cheque, need to have balance in account to cover or will hold until it clears

TD, 1070 Douglas St.
1) Two pieces of ID, one photo (at least), with signature
2) No
3) Only government cheques or cheque drawn at this branch; need two pieces of ID

Bank of Montreal, Box 1799
1) Two pieces of ID, one photo
2) Government cheque, or if cheque is from this branch
3) Two pieces of ID, one photo; hold on personal cheques for six days

Royal Bank, Franklin Ave.
1) Two pieces of ID, photo preferred (form asks questions re: SIN #, employment, address etc.)
2) No, must be drawn on the Royal
3) One photo ID

Canada Trust, 11550 - 104 Ave.
1) Two pieces of ID, one with photo and current address
2) Yes, up to a certain amount, if it is drawn on an account at the branch and you bring two pieces of ID
3) Same as (1); hold for five days on AB cheques, 10 days if from elsewhere

Canadian Western Bank, 103 St. and Jasper Ave.
1) Two pieces of ID, official, one photo; credit check and $20 deposit
2) Yes
3) Two pieces of ID, one official photo ID, and has to have signature

Canadian Western Bank, 11350 Jasper Ave.
1) Three pieces of ID, one with photo
2) Only if drawn on account at this branch, and you have two pieces of ID
3) Same as (1)

CIBC, 11504 - 104 Ave.
1) Two pieces of ID
2) Only if drawn on account at this branch
3) Hold policy for the first three to six mo.

Hongkong Bank, 10561 Jasper Ave.
1) Credit checks done (won't open account if bad credit); two pieces of ID, one official photo
2) Yes
3) Two pieces of ID, one official photo and signature and another bank card, birth certificate etc.

Laurentian Bank, 103 St. and Jasper Ave.
1) Two pieces of ID, one photo; credit check done
2) No
3) Two pieces of ID, one photo

Royal Bank, 11604 - 104 Ave.
1) Two pieces of ID
2) No
3) Depends on your client card

Scotiabank, 11508 Jasper Ave.
1) Two pieces of ID
2) Yes
3) Same as (1)

Scotiabank, 95 St. and 111 Ave.
1) Two pieces of ID; need permanent address or mailing box, but not general delivery address
2) Yes
3) Two pieces of ID

TD Bank, 11740 Jasper Ave.
1) Two pieces of ID, at least one signed with current address; ID from Money Mart not acceptable
2) No
3) Depends on profile -- similar to a credit inquiry

Canada Trust, 179 2nd Ave. S.
Comment: Surveyors were told they would have to wait an hour to make an appointment to see someone about opening an account. No information was provided. Treatment was very brisk. Surveyors were brushed off and turned away quickly.

Canadian Western Bank, 244 2nd Ave. S.
1) Three pieces of signed ID
2) No
3) Same as (1)

CIBC, Circle Dr. and Faithfull
1) Two pieces of signed ID
2) No
3) Two pieces signed ID

Hongkong Bank of Canada, 321 21st St. E.
1) Three pieces of signed ID, SIN number
2) No
3) Account, and three pieces of signed ID

Laurentian Bank of Canada, 183 2nd Ave. S.
1) Two pieces of government ID, need SIN number and preferably photo ID; must do credit check; need former addresses for last two years and other personal information; asked re job and source of income
2) No
3) If account, still need two pieces of signed ID

National Bank of Canada, 116 2nd Ave. S.
1) Two pieces signed ID, no photo ID required
2) Only federal government cheque, or have an account at our branch
3) Two pieces signed ID

Scotiabank, The Centre at Circle and 8th St. E.
1) Three pieces of ID
2) Yes
3) Three pieces of ID; hold for 15 days

Scotiabank, Circle Dr. and Faithfull
1) Two pieces of signed ID
2) Only if federal government cheques
3) Two pieces signed ID

Bank of Montreal, 1800 Scarth St.
1) Two pieces of ID
2) Only government cheques, or on their accounts; $3.00 cashing fee
3) Two pieces of ID

CIBC, 1800 Hamilton
1) Two pieces of ID
2) Only government cheques, or on their accounts
3) Two pieces of ID

Hongkong Bank of Canada, 1874 South St.
1) Two pieces of ID
2) Only government cheques, or on their accounts
3) Two pieces of ID

Laurentian Bank, 1862 Hamilton
1) Two pieces of ID (signature)
2) Only government cheques, or on their accounts
3) Two pieces of ID

National Bank, 1863 Victoria Ave.
1) Two pieces of signature ID (SIN card pref.)
2) Only government cheques, or on their accounts
3) Two pieces of ID

Royal Bank, 11th and Hamilton
1) Two pieces of ID
2) Only government cheques, or on their accounts
3) Two pieces of ID

Scotiabank, 11th and Hamilton
1) Two pieces of ID (sign)
2) Only government cheques, or on their accounts
3) Two pieces of ID

Bank of Montreal, 333 Main
1) Three pieces of ID, with photo
2) No
3) Bank card or three pieces of ID, and an open account

Bank of Montreal, Main and Portage
1) Drivers licence with photo and SIN
2) No
3) If account, bank card or chequing endorsement

Bank of Montreal, 1151 Portage Ave.
1) Two pieces of ID, one photo; surveyor was asked if she had a job
2) Yes
3) Two pieces of ID w/ photo, and preferably an account with the bank

CIBC, 201 Henderson
1) Two pieces of ID
2) Yes, if government or drawn on local branch
3) Government ID or instant teller card or credit card

CIBC, 955 Henderson Hwy.
1) Two pieces of ID
2) Depends on the cheque
3) Two pieces of ID

CIBC, Richardson Bldg.
1) Drivers licence with photo, and one credit card
2) No
3) One piece of ID

Canada Trust, 1128 Henderson
1) Two pieces of ID, signed, one photo
2) Yes, only government though
3) Only government, same ID as (1)

Canada Trust, 230 Portage
1) Three specific pieces of ID: Driver's licence (w/ photo), MB health card, and SIN card
2) No
3) Bank card if at same branch as account; at other branches, two further pieces of ID; cheques would be only be cashed up to amount in account for "covering" purposes

TD Bank, TD Bank Bldg., 201 Portage Ave.
1) Driver's licence with photo, second ID with address
2) No
3) Bank card

Canada Trust, 230 Portage Ave.
1) Three specific pieces of ID required: driver's license (w/ photo), Man. Health Card, and SIN card
2) No
3) If account, bank card; if other branch, two pieces of ID also required; cheques only cashed up to the amount in your account (for "covering" purposes)

Canadian Western Bank, 234 Portage Ave.
1) One piece of ID with photo, one piece of ID with home address, AND credit card
2) Yes (but see (3))
3) Sufficient ID (two pieces) for a $75 to $100 GOVERNMENT cheque or equivalent

Hongkong Bank, 240 Graham
1) One piece of ID with address, SIN card, AND credit card
2) See (3)
3) Federal government cheques will be cashed up to $1,200 with reasonable ID (driver's licence with photo, home address, valid, etc.)

Laurentian Bank, 221 Portage Ave.
1) Driver's licence with photo, SIN card or credit card, AND one ID with address
2) No
3) n.a.

National Bank, 191 Lombard
1) Photo ID, SIN card AND credit card
2) No
3) Nothing; not even their bank card; they will check your endorsement against your signature on file

Royal Bank, 220 Portage Ave.
1) Two pieces of ID, one photo
2) See (3)
3) Two pieces of ID, one photo, only if cheque is made out to Royal Bank
NOTE: second survey of this branch responded that you can cash cheques if it is a reasonable amount and from a government or a well-known company and you have several pieces of ID

Scotiabank, Portage and Main
1) Two pieces of ID, one photo (otherwise, three to four pieces required) -- checklist includes SIN
2) No
3) In June, will require "swiping" your bank card, and use of an identifying number

Bank of Montreal, 270 Dundas St.
1) Three pieces of ID, one photo
2) No (not even government check)
Comments: Credit check will determine what type of access card you will get

Canada Trust, 275 Dundas St.
1) Three pieces of ID, one photo
2) Only if government cheque, otherwise no
3) If government cheque, three pieces of ID, one photo

CIBC, 166 Dundas
1) Two pieces of ID, usually one photo
2) See (3)
3) If cheque is government or drawn on the same branch, three pieces of ID, one photo, plus $3.00

Hongkong Bank, Wellington and King St.
1) Three pieces of ID with one being a photo government-issued ID, or credit card
2) Yes, but only government cheque, or if the cheque is drawn on the branch
3) Three pieces of ID, one photo

Laurentian Bank, 150 Dufferin Ave.
1) Three pieces of ID, one with photo, credit check mandatory
2) No
3) Bank card if dealing with another branch

TD Bank, 365 Richmond
1) Two pieces of ID, one photo
2) See (3)
3) If check is drawn on this branch or government cheque, two pieces of ID, one photo ID, not health card

TD Bank, 267 Dundas
1) Three pieces of ID, one photo
2) See (3)
3) If cheque is drawn on this branch or government cheque, two pieces of ID, one photo ID, not health card

Royal Bank, 383 Richmond
1) Two pieces of ID, issued by government or financial institution, photo not required
2) See (3)
3) If cheque is government or drawn on this branch, two pieces of ID

Scotiabank, 420 Richmond
1) Surveyor was first asked if she had a job, then was referred to staff to open the account
2) No, not even government cheque

Bank of Montreal, 568 College St.
1) Two pieces of ID, one photo
2) No

Bank of Montreal, 4700 Keele St.
1) Three pieces of ID, one photo
2) No -- only cheques drawn on the branch

CIBC, 641 College St.
1) Two pieces of ID, one photo
2) No

CIBC, 3040 Keele St.
1) Two pieces of ID
2) No -- only cheques drawn on the bank, or government cheque

Royal Bank, 429 College St.
1) Two pieces of ID, one photo; must live or work in area; health cards, metropasses are not valid
2) Depends on origin of cheque (i.e. from which account the cheque is being drawn from)
3) Two pieces of ID, one photo

Scotiabank, 643 College St.
1) Photo ID, SIN, and major credit card
2) Without account, only government cheques up to $1,500 cashed
3) Two pieces of ID, one photo; hold period depends on income level

TD, 443 Queen St. W.
1) Two pieces of ID
2) Only cheques drawn on an account at the branch
3) ID

TD, 3931 Keele St.
1) Two pieces of ID; one must be photo, and social insurance number
2) No -- must be drawn on an account at the branch

* = Surveyed in 1997 by the CCRC

Bank of Montreal, 160 Elgin St.
1) Three pieces of ID, incl. one photo ID
2) No
3) First 30 days of the account, six-day hold; then we see how account develops

Bank of Montreal, 144 Wellington
1) "Good" ID required (staff was vague); must make an appointment to open account
2) No

Canada Trust, 45 O'Connor
1) Three pieces "solid" ID, photo ID and credit card
2) No

Canada Trust, 170 Laurier Ave.
1) Photo ID a must -- egs. driver's licence, birth certificate
2) No, unless account at CT
3) Hold period, for first six months, of up to six days

CIBC, 168 Laurier Ave.
1) Passport, driver's licence or credit card
2) Only government issued or issued at this branch
3) Depending on Credit Bureau check. We give you only $300. Any amount above that is subject to six-day hold.

*CIBC, Rideau and Sussex Dr.
1) Two pieces of ID (although staff repeatedly mentioned photo ID as examples)
2) No
3) Five-day hold for new accounts, especially if not from big (well known) company
Comment: This branch was not in compliance with the new accounts promise in 1997.

Hongkong Bank of Canada, 30 Metcalfe St.
1) One piece of primary ID (photo or credit card), plus three secondary IDs
2) Judgment call by the teller, since it's their "ass" on the line
3) Need ID; five-day hold

Laurentian Bank, 255 Albert St.
1) Two pieces of signed ID with photo, or credit card, and original copy of lease
2) No
3) New accounts have seven-day hold period (for period up to six months)

National Bank, 282 Elgin St.
1) Photo ID
2) Only government cheques
3) Government photo ID or credit card; first cheque, 28-day hold period; six-day hold period "once we know you."

National Bank, 50 O'Connor St.
1) Two pieces of photo ID; if unemployed, you must notify when you find work and provide employer information; if student, must give school information
2) No
3) If cheque is a company or government cheque, no hold; but if personal cheque, six-day hold

*National Bank, 242 Rideau St.
1) Two pieces of government-issued ID, one photo ID
2) No
3) First month, hold for five days; if "good profile" after a month, it can be cashed the same day Comment: This branch was the only bank found to be in compliance with the new accounts promise in 1997.

Royal Bank, 200 Elgin St.
1) Two pieces of ID, ideally passport or SIN card
2) Only government cheque
3) ID; if account, three-day hold period, until "we get to know you."

*Royal Bank, 90 Sparks St.
1) Two pieces of ID with signature (exception health card)
2) Only cheques issued by this branch
Comment: This branch was not in compliance with the new accounts promise in 1997.

Scotiabank, 180 Elgin St.
1) Three pieces of ID; we must verify residence and employment; re "unemployed" -- "In this particular branch, we won't open an account if you are unemployed. We only deal with professionals. But any other branch will take you."
2) No
3) Six- to 10-day hold period on cheques

Scotiabank, 119 Queen St.
1) Two pieces of ID
2) No -- must go to originating bank

*Scotiabank, 50 Rideau St.
1) Two pieces of ID; "we need to verify address and employment;" surveyor was asked, "Are you employed." She responded that she was not. She was then told, "We need to see a copy of your lease."
2) No, unless cheque was issued by Scotiabank
3) No hold on government cheques; otherwise five to seven business days Comment: This branch was not in compliance with the new accounts promise in 1997.

TD, 263 Elgin St.
1) Three pieces of ID, incl. one photo ID
2) No, must have account here
3) Six-day hold on personal, three-day hold on government

*TD, 303 Rideau St.
1) Two pieces of ID, one photo
2) No, Must go to originating bank
Comment: This branch was not in compliance with the new accounts promise in 1997.

TD, 106 Sparks St.
1) Photo ID; surveyor asked "Are you in the phone book," and told "We need to verify employment and address."
2) No, unless cheque drawn on the same branch
3) After 120 days or six months, if good relationship has been established with the customer, there are no holds on personal cheques.

Bank of Montreal, 1805 Jean Talon E.
1) Lease, two pieces of ID, and credit check
2) No
3) Open account, hold five to 30 days

Bank of Montreal, 5651 Verdun Ave.
1) Lease, two pieces of ID, and credit check
2) No
3) Open account, hold five to 30 days

Canada Trust, 999 de Maisonneuve Boul. W.
1) Three pieces of government ID with signature and at least one photo such as signed SIN, Driver's License, Health Care Card
2) No
3) Open account, and we will hold funds from five to 20 days

Hongkong Bank of Canada, 88 Rene Levesque W.
1) Living nearby lease, and two pieces of ID
2) No
3) Open account seven days or more, hold funds for seven to 30 days

Laurentian Bank, 4214 Wellington
1) Lease, SIN and medicare cards
2) No
3) Open account, hold account three days local, hold ten days other province up to 30

Royal Bank, 5437 Verdun
1) Lease, two pieces of ID and credit check
2) No
3) Account, hold for two to three days or more

Scotiabank, 55 Mont Royal Ave. W.
1) Lease, two pieces of ID, credit check, and must live in the area
2) No
3) Open account, hold six to 30 days

TD Bank, 5290 Verdun
1) Lease, two pieces of ID, and credit check
2) No
3) Open account, hold five to 30 days, cash held five days

Bank of Montreal, 238 Water St.
1) Two pieces of ID, including one photo ID; if no photo ID available, need three pieces
2) No cashing of social assistance cheque because any cheque cashed without an account has to be drawn on a Bank of Montreal affiliate and social assistance cheques are "CIBC drawn"
3) n.a.

Canada Trust, 240 Water St.
1) Two pieces of ID, including one with photo, or three signed IDs if no photo ID presented
2) No
3) Five-day hold on every cheque deposited "for the first month or so, to get used to your banking procedures"

CIBC, Atlantic Place
1) Two pieces of signed ID, including a photo ID and SIN card (worker added this when social assistance cheque was produced)
2) Social assistance cheque can be cashed because it is drawn on our bank
3) You definitely need SIN if you don't have an account, and one other signed government ID (total of two government IDs)

Hongkong Bank, 205 Water St.
1) Two pieces of ID
2) Except for social assistance cheques, which will not cash (referred to CIBC); hold of 10 days if the cheque is from St. John's, and two weeks if from out of province
3) Same as (1)

National Bank, 189 Water St.
1) Photo ID, but when asked, bank staff said SIN is a must and then added "but we are not supposed to ask you about that; we do because we are wary of fraud."
2) No, we send those wanting to cash social assistance cheques to CIBC
3) Photo ID

Royal Bank, 226 Water St.
1) Two pieces of ID, not necessarily with a photo
2) Yes, can cash social assistance cheque
3) Same as (1)

Scotiabank, 245 Water St.
1) Two pieces of ID, no picture required
2) Yes
3) Same as (1)

TD Bank, Water Street
1) Driver's license is a must, as is a SIN; You need two IDs and at least one must be a photo ID
2) Can't cash social assistance cheque, but can cash a cheque if it's drawn from our bank
3) Same as (1) for cheque drawn on our branch
Comment: Women waited 10 minutes before being served; reception desk was empty and nobody offered to help