Ranking New York's Banks: Comparing the Products and Services of the Nineteen Largest Banks Serving Consumers in the Empire State

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Ranking New York’s Banks:
Comparing the Products and Services of the Nineteen Largest
Banks Serving Consumers in the Empire State
Primary Authors:
Ray Brescia, Associate Professor of Law, Albany Law School
Ralph Scunziano, Albany Law School, Class of 2016
Additional Contributions by:
Kirsten Keefe, Barbara VanKerkhove, and Jack Kelly, Empire Justice Center
Jaime Weisberg, Association for Neighborhood & Housing Development

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Ranking New York’s Banks:
Comparing the Products and Services of the Nineteen Largest Banks
Serving Consumers in the Empire State.
New York State is one of the financial
capitals of the world, and individual
consumers of banking services have a
wide range of commercial banks to
choose from, all of which provide a
dizzying array of products and services.
With the details of many of these
products and services buried in the fine
print of consumer agreements or in the
back pages of bank websites, the
consumer is sometimes at a loss when
choosing which bank to use as his or
her primary bank when looking to open
a checking account, use an ATM, send
a remittance, or open a credit card
account. The New York Bank Ranking
Index (NYBRI) attempts to take some
of the guesswork out of choosing a
bank. It evaluates the nineteen largest
banks in New York State by awarding
points to each bank based on how well
the banks meet consumer needs in
twenty consumer-focused categories.
In its current form, the NYBRI weighs
each of these categories equally. The
index then ranks the banks by giving a
cumulative score under each category
and lists them out highest to lowest.
Consumers can also go to the
accompanying website, www.nybri.org,
to customize a ranking based on their
own preferences in terms of the
categories to use in scoring the banks
and the relative weights to assign these
categories. This report provides
background information on the NYBRI,
explains the process by which we
completed the ranking and scoring for
the nineteen largest banks serving
individual bank customers in New
York State, scores the banks and offers
the final ranking, and then supplies the
individualized data for each bank in an
appendix. While we focus on New York
State in this study, other jurisdictions
can utilize the methodology used here
for their own communities.
1.0 Background.
1.1. Authors and Contributors.
The primary authors of this
report and study are Ray Brescia and
Ralph Scunziano, a professor at Albany
Law School and a recent graduate of
the law school, respectively. Additional
assistance was offered by the following
individuals: Kirsten Keefe, Barbara
VanKerkhove, and Jack Kelly, of the
Empire Justice Center; and Jaime
Weisberg, of the Association for
Neighborhood & Housing
Development.
1.2 The Purpose of This Study.

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The purpose of this study is to
assess the quality and range of
products and services offered by banks
serving individual consumers in New
York State. In turn, it takes that
assessment and ranks the banks
according to how well they perform
under that assessment relative to each
other. While banks offer a wide range
of products and services to businesses
small and large, this study focuses on
the products and services that are of
the most interest to individual bank
customers, such as credit cards,
checking accounts, check-cashing, and
home mortgage lending. Additionally,
this study focuses on commercial
banking and not investment banking,
although many of the banks discussed
here offer both types of services to their
customers. The specific categories of
products and services and the
methodology for scoring the banks
under each category is explained in
further detail in Sections 1.5 and 2.0.
1.3 Some Background on Bank
Rating.
In the 1960s and 1970s, the Civil
Rights Movement exposed how bank
practices contributed to community
destabilization through practices such
as redlining (denying certain
communities services and products on
fair terms, typically based on the race
of the community) and disinvestment
or capital exportation (taking deposits
from one community and putting them
to work in other communities). In light
of a growing awareness of how bank
practices contributed to community
decline, Congress passed the Home
Mortgage Disclosure Act in 1975
(HMDA), and, two years later, the
Community Reinvestment Act (CRA).
These two federal laws were designed
to combat the twin problems of
redlining and capital exportation.
First, HMDA requires banks to reveal
their home mortgage lending practices
by providing demographic information
on the prospective borrowers seeking,
receiving and being denied home
mortgages. Through the CRA, federal
bank regulators assess the extent to
which banks are meeting the
“convenience and needs” of the
communities they serve, with a
particular focus on low- and moderate-
income communities. Banks are given
a grade by regulators on the extent to
which they meet such convenience and
needs, and the regulators are supposed
to take into account the grade the
banks receive under the law when
considering applications by those
banks to engage in certain conduct
requiring regulator approval, such as a
merger with another bank.
With these two laws in place,
regulators and community activists
tried to keep tabs on bank behavior to
make sure they were meeting
community needs. Regardless of the
existence of these laws, the S&L Crisis
of the 1980s and press accounts of the
lasting vestiges of redlining in the early
1990s brought about calls for

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strengthening both laws. Regulators
passed new regulations in the 1990s
related to the CRA that gave clearer
guidance to banks as to how to meet
their obligations under the law.
Despite such efforts, the banking
crisis of the late 2000s, and the Great
Recession and foreclosure crisis that
both followed in its wake, exposed the
remaining weaknesses of the CRA and
HMDA laws. As numerous accounts
have made clear of the events that led
to the economic turmoil of that period,
financial institutions operating outside
of the scope of the CRA engaged in
risky lending, often with a racial tint,
that impacted communities of color and
low- and moderate-income
communities disproportionately.
Making matters worse, despite the
risky behavior of many banks in the
lead up to these crises, a staggering
ninety-eight percent of banks received
passing grades under the CRA in the
mid-2000s, the period when financial
institutions engaged in practices
harmful to the very communities the
CRA was designed to protect.
In addition to the apparent
inability of the CRA to prevent harm
from coming to the very communities it
was designed to protect, advocacy
groups have complained that the CRA
process is a “black box”: it is
undertaken by bank regulators mostly
in secret and the community is
unaware of many of the factors that go
into the grades banks receive. While
the public does have the ability to
provide comments and can access a
bank’s CRA report, as well as the final
“grade” the bank receives from its
regulator, much of the information the
banks turn over to the regulators for
the purpose of generating the CRA
grade is unavailable to the general
public.
In addition to the lack of
transparency surrounding the CRA
process, advocates have also
complained that the criteria regulators
use to determine a bank’s grade does
not include a range of factors that
might be important to consumers of
banking services, like the array of
products and services that might be
offered by the banks. As a result,
advocates have begun to look for
alternative means of measuring the
extent to which banks are meeting the
needs of the typical banking customer.
The first of these efforts was
started in the city of New Haven, CT,
in 2012. There, city officials, aided by
law students and faculty of Yale Law
School, compiled New Haven’s
Community Impact Report Card
(CIRC). The CIRC assessed the
products and services offered by the
eleven banks serving the greater New
Haven area. This initial report was
updated by the City in 2014. In
addition to the CIRC, several
nonprofits have created index-like
systems for assessing and grading
bank practices. The Association for
Neighborhood and Housing Developers
conducts an analysis of bank

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reinvestment in New York City using
an approach that is similar to a
banking index. In addition, the
Maryland Consumer Rights Coalition
has created a bank scoring index that
looks at the ways that banks in
Baltimore, MD, are providing services
that cater to the city’s aging
population.
The NYBRI is the first indexing
system that looks at the largest banks
operating on a state-wide level, in this
case, those banks serving consumers in
New York State. The goal of this study
is to provide consumers from across
New York State with a means of
comparison shopping between the
banks operating in the state so that
they might make educated decisions
about the bank that best meets their
individual banking needs.
The goal of the indexing
approach is to provide consumers with
a meaningful way of gauging the
products and services offered by the
banks that serve their communities.
The approach used through the NYBRI
and other bank indexing systems is to
offer salient and transparent metrics
for assessing bank products and
services. The goal of a consumer
indexing system is twofold. First, it is
designed to offer consumers a fair
means of comparison shopping
between banks. Second, once
consumers begin to utilize the index to
make choices about the bank they will
patronize, the hope is that such
consumer behavior will lead banks to
improve the products and services they
offer in light of such consumer banking
preferences.
1.4 Choice of Banks to Study in
the NYPRI.
In selecting which banks to
review for this study, we reviewed the
size of the commercial banks operating
in New York State based on
information from the Federal Deposit
Insurance Corporation (FDIC) by the
number of branches in the state and
the market share of the banks
according to the value of their deposits
in the state. Assessing these two
figures revealed that there was a
significant drop off in the number of
bank branches after 75 branches.
While JP Morgan Chase—with over
800 branches, had substantially more
branches than any other bank,
eighteen banks had between 75 and
200 branches, while the next bank
below 75 branches had only 49
branches. We then looked at market
share by deposits and determined that
banks with more than 75 branches
tended to have at least 0.75% market
share by deposits. Accordingly, we
identified the banks operating in New
York State that had at least 75
branches and enjoyed at least 0.75%
market share by deposits, thus yielding
the nineteen banks assessed for this
study. (During the period in which this
study was conducted, the purchase of
First Niagara Bank by Key Bank had
been proposed, but was not yet

5
finalized; as a result, we conducted
separate scoring for the two banks
through our analysis.)
1.5 Methodology.
The primary methodology for
conducting this study involved first,
creating a range of categories that we
believed were most important to
consumers when choosing the bank
where they want to bring their
patronage for items such as checking
accounts, credit cards, home mortgage
loans, and check cashing. With a goal
of reaching a familiar high cumulative
score of 100, we awarded a possible
high score of five points within each of
the twenty categories. As more fully
described below, these five points
within each category represented our
assessment of the extent to which a
given bank, under any particular
category, was providing strong
products or services (in which case the
bank was awarded five points) or was
particularly weak in that category (in
which case the bank was awarded just
one point). A bank did not have to
receive either the highest or lowest
score in a category, however. We
awarded between two and four points
to the banks under each category based
on our assessment of the strength of
those bank’s products or services along
a continuum particular to each
category. Furthermore, in certain
categories, we created objective
scoring; e.g., we gave banks points
based on their satisfying certain pre-
determined metrics, as in the overdraft
practices category. In other categories,
we used relative scoring by awarding
points based on the banks’ performance
compared to other banks in the study,
which was the case for our categories
based on the HMDA data of the banks.
The following section provides a
category-by-category description of our
methodology and the point values
ascribed within each category.
2.0 Description of the
Categories and Scoring
under Each Category.
2.1 Total Number of Branches.
The banks in this study received
two scores regarding bank locations.
The first score was based on the total
number of branches located in New
York State as of June 30, 2015. Branch
locations were defined as full service,
brick and mortar offices and full
service, retail offices. The bank branch
data was received from the National
Community Reinvestment Coalition
(NCRC), which obtained the data from
the FDIC. All the banks in the study
were given the opportunity to provide
updated data in this category. If they
provided updated data under this
category, we accepted it and
incorporated it into our findings. There
was one extreme outlier in this
category: JP Morgan Chase bank,
which had roughly 800 branches, while
Bank of America was a distant second
with 321 branches. Because of this, the
method used to score this category was

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to first put market share values in
order from lowest to highest. Since
there were nineteen banks in the
study, the first three banks (with the
lowest market shares) received a score
of one, the next four banks received a
score of two, the next five banks
received a score of three, the next four
banks received a score of four, and the
final three banks (with the highest
market shares) received a score of five.
This was designed to create a bell curve
for this particular category given the
extreme outlier.
2.2 Percentage of Branches in
Low- and Moderate-Income
Areas.
The next score was based on the
distribution of branches in low- and
moderate-income (LMI) areas. The
same data was used, with the FDIC
providing geocoding for the LMI areas.
The NCRC used the FDIC geocode
information to map the branches. The
number used for the category was the
percentage of branches in LMI areas.
As with all information used in this
study, we reached out to the banks that
were included in the study to request
any additional/corrective information
they might possess with respect to the
study. If a bank offered us different
data with respect to this category, we
used it and incorporated it into our
study.
The raw percentages taken from
the NCRC data were converted into
scores for each bank between one and
five. In order to do so, the percentage
for the bank being assigned a score
(hereafter referred to as “B”) was
subtracted by the lowest percentage of
all the banks in this category, which
was approximately 12% in this
category, (B – 12%). This was used as
the numerator in the scoring equation.
The denominator was the highest
percentage in this category,
approximately 30%, subtracted by the
lowest percentage, or the range of
percentages, of all the banks in the
study, (30% – 12%). This produced a
percentage between 0% and 100%. %=
(B – 12%) / (30% – 12%). The banks
were then divided into quintiles based
on the outcome of this calculation and
scores were then assigned to each bank
based on the quintile to which they
were assigned:
0%–20% received a score of 1
>20%–40% received a score of 2
>40%–60% received a score of 3
>60%–80% received a score of 4
>80%– 100% received a score of 5
As an example of how we calculated the
score in this category, the lowest
approval rate of all nineteen banks in
the study is 12.51% and the highest is
36.77%. In order to determine where a
particular bank fell within that range,
we subtracted the lowest point
(12.51%) from that bank’s actual
score. One institution, NBT Bank, had
26.59% percent of branches in Low-
and Moderate-Income areas. We
subtracted the lowest rate
(12.51%) from NBT’s rate (26.59%) to

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get a figure of 14.08%. We then looked
at the range of 24.26% (lowest score
subtracted from the highest score), and
placed NBT’s adjusted score on that
range. It ended up with a score of 14.08
percentage points out of a possible
24.26 percentage points, meaning the
bank placed at 58% of the range, giving
it a score of 3 points out of 5 for this
category.
2.3 Online Banking.
The online banking category was
based entirely on the features and
options that banks in the study make
available to its customers or members.
The features that were common and
determined to be vital to the scoring
rubric were Applications (Apps),
Mobile Banking, Online Banking, and
Text Banking. Apps are defined for
this study as any downloadable
application that can be used on a
cellular phone or other computer and
can be used to perform basic banking
functions. Mobile Banking is defined
as having basic banking functions
available through the use of a mobile
phone with internet access without
using an application. Online banking
includes being able to perform basic
banking functions through a computer
using the bank’s website. Text banking
is defined as allowing basic banking
functions to be performed through the
use of text messages directly to the
bank. The banks were also evaluated
for the ease at which their websites
could be navigated. The bank either
received a “user-friendly” designation
or a “not user-friendly” designation
based on their website. Banks were
only deemed “not user-friendly” if their
website was very difficult to navigate
and information about services was
hard to find.
If the bank was missing two or
more of the described features and was
not user-friendly, it received one point
for this category. If the bank was
missing one option and was not user-
friendly, it received two points. If there
was only one option missing and the
website was user-friendly, the bank
received three points. If the bank had
all four features but was not user-
friendly, a score of four points was
assigned. Finally, if the bank had all
four features and was user-friendly, it
received a score of five points for this
category.
2.4 ATM Fees Outside of
Network.
In this category, each bank was
assigned a score based on the fees that
customers are charged for using ATMs
that are outside of the bank’s network.
The fees ranged from $1.00 to $3.50.
The scoring rubric was created using
this range as the basic framework.
Banks that charge either $3 or
more per withdrawal for an ATM that
is outside of the bank’s network
received a score of one point for this
category. Banks that charge less than
$3, but more than $2, received a score

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of two points. Banks that charge a $2
fee received three points for this
category. Banks that charge less than
$2 but more than $1 received a score of
four points. Banks that charge either
$1 or less received five points for this
category.
2.5 Checking Account Fees
(Basic Level or Checkless
Checking Account).
For this category, either the
checkless checking account or the basic
level checking was used. The basic
level checking account was chosen as
the one with no extra features and the
lowest minimal amount requirement to
open and/or lowest fee balance
maintenance requirements.
Points in this category were
awarded for features that we believe
are important: consumer-focused
features for checking accounts. When
scoring a particular checking account,
one point was given for those accounts
which had an unlimited number of
transactions allowable (without
charging a fee). One point was given
for banks that had a minimum initial
opening deposit of $25 or less. One
point was given for monthly
maintenance fees of $5 or less (if the fee
is not waivable) OR $10 or less if the fee
is waivable by a single transaction
(with at least two options such as direct
deposit with no minimum deposit,
online bill pay or debit card purchase).
One point was given for accounts that
had no Overdraft fees or Non-Sufficient
Funds (NSF) Fees. Finally, one point
was given for accounts that had no
dormancy or inactivity fees. All banks
had at least one of these features so we
could easily assign a point range of one
through five in this category.
2.6 Savings Account Fees (Basic
Level Account).
For this category, we used the
most basic level savings account. We
chose the basic level savings account as
the one with no extra features and the
lowest minimal amount requirement to
open and/or the lowest fee balance
maintenance requirements.
The two amounts that were
considered in this category were the
minimum amount necessary to open
the account and the fees charged on a
monthly basis. Many accounts offer a
waiver of this fee if a certain monthly
balance is maintained, so this was also
factored into the scoring rubric.
For basic level savings accounts
that have a minimum amount to open
the account at $400 or more and/or fees
are not waivable or waived when a
monthly balance of $2,000 or more is
maintained, the bank received one
point in this category. For accounts
that had a minimum amount to open at
$250 or more (but less than $400)
and/or fees that are waived at a
monthly balance of $1,000 or more (but
less than $2,000), the bank received
two points. For accounts that had a

9
minimum amount to open at $100 or
more (but less than $250) and/or fees
that are waived at a monthly balance of
$500 or more (but less than $1,000), the
bank received three points. For
accounts that had a minimum amount
to open at less than $100 (but more
than $1) and/or fees that are waived at
a monthly balance less than $500, the
bank received four points. For
accounts that have no minimum
amount to open or a nominal amount of
$1 and/or have no monthly fees for
accounts their basic savings account
regardless of monthly balance, a score
of five points was assigned for this
category.
2.7 Overdraft Practices.
For this category, we used the
basic level checking. (The checkless
checking account was not considered
because no overdraft is possible with
those accounts because of the nature of
the account.) The basic level checking
account was chosen as the one with no
extra features and the lowest minimal
amount required to open and/or the
lowest fee balance maintenance
requirements. We ascertained each
bank’s overdraft practices through that
bank’s individual website or through a
call placed to a representative of the
bank.
We chose four metrics to create
the scoring rubric for this category.
One point was awarded for banks that
had overdraft fees that were both
clearly disclosed and complete (listing
all of the fees and practices). We
determined whether a disclosure was
clear based on whether a given bank
disclosed the fees and practices in the
description of the account fees in a
place that was easily located on that
bank’s website. Banks did not receive
a point for this feature if the all of the
fees and practices were not listed in the
description of the account fees. One
point was given to accounts which did
not allow ATM overdrafts or Point of
Service (POS) debit card overdrafts.
(ATM and debit card overdrafts are
debit card charges where the customer
is paying, in person or over the
internet, with his or her debit card.)
Lastly, we awarded a point for accounts
where the order of processing
transactions was from the lowest
amount to the highest amount.
Processing transactions this way
results in fewer overdrafts and
potentially lower fees. Since there
were four features in this scoring
rubric, if an account had none of these
feature, the bank received one point. If
a bank had one feature, it received two
points, and so forth, for a potential total
of five points.
2.8 Overdraft Limits and
Amounts.
This category was established to
measure the fees charged for
overdrafts. Instead of attempting to
squeeze the dollar amounts for
overdraft penalties in the previous
category (overdraft practices), we

10
created a separate category. We
decided that overdraft practices were
separate and apart from the amounts
charged by banks for overdrafting an
account. Additionally, it was very
difficult to incorporate the dollar
amounts with qualitative measure of
the standards used to determine
overdraft practices.
The two numbers we used in this
category included the amount charged
for each overdraft and the maximum
amount of overdrafts charged by the
banks before an additional overdraft
was not allowed (e.g. a check/debit
purchase is bounced/declined). We
multiplied these two numbers to
determine each bank’s maximum
dollar value of fees that a customer
could potentially incur before the
account does not allow any more
charges.
The highest potential fees
charged by the banks evaluated,
besides one which did not have any
limit on the fees, were $245, and the
lowest potential fees, besides one bank
which did not charge any overdraft
fees, were $102. The denominator of
the formula used for scoring used the
difference between these two numbers
(245 – 102). The numerator used for
each bank was that particular bank’s
(B) total fees subtracted by the lowest
potential fees of all the bank’s
evaluated (B – 102). %= (B – 102) / (245
– 102).
Using this formula, those banks
whose fees were between 0% and the
20% percentile were assigned a score of
five points. The banks whose fees were
greater than the 20th percentile and up
to and including 40% were assigned a
score of four points. The banks whose
fees were greater than the 40th
percentile and up to and including 60%
were assigned a score of three points.
The banks whose fees were greater
than the 60th percentile and up to and
including 80% were assigned a score of
three points. The banks whose fees
were greater than the 80th percentile
and up to and including 100% were
assigned a score of one point. The bank
with no limits to the amount of
overdraft fees charged received one
point. The bank that did not charge
overdraft fees at all received five
points.
2.9 Credit Cards (Basic
Unsecured) (As Compared to
Average APR Range).
In this category, we evaluated
the most basic, unsecured credit card
offered by each bank. We ignored those
with point reward programs and those
that required higher credit scores to
obtain. The annual percentage rate
(APR) range, as compared to the
average APR of all the banks
evaluated, was the sole factor used in
this category.
In order to assign a score, the
exact middle point of the APR range
was taken (upper end subtracted by
lower end, and then divided by two) for
each bank. At this point, we used the

11
highest value and the lowest value of
all banks evaluated as the denominator
for the formula (highest middle point
minus lowest middle point). The
numerator for each bank was its exact
middle point of the APR range minus
the lowest middle point of the APR
range out of all banks evaluated.
Using this formula, we assigned
those banks with an exact middle point
of the APR range between 0% and 20%
a score of five points. We assigned the
banks with an exact middle point of the
APR range were greater than the 20th
percentile and up to and including 40%
a score of four points. Banks with an
exact middle point of the APR range
were greater than the 40th percentile
and up to and including 60% received a
score of three points. The banks with
an exact middle point of the APR range
were greater than the 60th percentile
and up to and including 80% received a
score of three points. The banks with
an exact middle point of the APR range
were greater than the 80th percentile
and up to and including 100% received
a score of one point. The bank received
one point if they did not offer credit
cards.
2.10 Credit Card Late Fees.
For this category, we compared
the maximum late fee charge by the
banks on a late payment for the same
basic, unsecured credit card used in the
prior category. The lowest fee of all the
banks evaluated was $25 and the
highest fee was $38. The denominator
of the formula used to determine the
bank’s score was this highest value
minus the lowest value (38 – 25). The
numerator was the fee that particular
bank (B) charged minus the lowest
value amongst all the banks (B – 25).
% = (B – 25) / (38 – 25). Using this
formula, those banks whose fees were
between 0% and 20% were assigned a
score of five points. The banks whose
fees were greater than the 20th
percentile and up to and including 40%
were assigned a score of four points.
The banks whose fees were greater
than the 40th percentile and up to and
including 60% were assigned a score of
three points. The banks whose fees
were greater than the 60th percentile
and up to and including 80% were
assigned a score of two points. The
banks whose fees were greater than the
80th percentile and up to and including
100% were assigned a score of one
point. The bank received one point if
they did not offer credit cards.
2.11 HMDA Categories.
We assigned scores to banks for
a number of categories regarding
mortgage loan acceptance (or
origination) rates, percent of total loans
going to different categories, and loan
origination market share using
information available through HMDA.
We found all information derived for
these categories in the U.S. Federal
Financial Institution’s Examination

12
Council’s 2014 HMDA data, the last
year for which this data was available
when we performed this study. The
data for the loans included first lien
home purchase and refinance loans on
owner-occupied, site-built residences
with one to four units.
These categories included the
following, with each item a separate
category in the index:
 the market share of loans
originated in NY State (or of
loans originated by the 19
banks),
 the loan acceptance rate in NY
State,
 the loan acceptance rate for
Latino borrowers,
 the loan acceptance rate for
Black borrowers,
 the loan acceptance rate for low-
and moderate-income borrowers,
 the percentage of total loans to
low- and moderate-income
borrowers,
 the loan acceptance rate in low-
moderate-income communities
(census tracts),
 the percentage of total loans in
communities of color (census
tracts with 50% or more non-
white residents).
The raw percentages taken from
the HMDA data were converted into
scores for each bank, awarding a score
between one and five points. In order
to do so, we took the percentage for
each bank being assigned a score (B)
and subtracted it by the lowest
percentage (Blowest%) for that category of
all the banks in the study. (B –
Blowest%). This was used as the
numerator in the scoring equation.
The denominator was the highest
percentage (Bhighest%) subtracted by the
lowest percentage for that category of
all the banks in the study, or the range
of percentages. (Bhighest% – Blowest%).
This process was repeated for each
bank in the study, producing a
percentage between 0% and 100%.
%=(B – Blowest%) / (Bhighest% – Blowest%).
Scores were then assigned to each bank
based on the following basis:
 >80%– 100% received a score of 5
 >60%–80% received a score of 4
 >40%–60% received a score of 3
 >20%–40% received a score of 2
 0%–20% received a score of 1
Here is an example to illustrate how
this was done. In the category titled
“Loan Approval Rate for Latino
Borrowers,” the lowest approval rate of
all 19 banks in the study is 19.44% and
the highest is 75%. In order to
determine where a particular bank fell
within that range, we subtracted the
lowest point (19.44%) from that bank’s
actual score. Bank of America had an
approval rate for Latino borrowers of
32.85%. We subtracted the lowest rate
(19.44%) from Bank of America’s rate
(32.85%) to get a figure of 13.41%. We
then looked at the range of 55.56%
(lowest subtracted from highest), and
placed Bank of America’s adjusted
score on that range: They received
13.41 percentage points out of a

13
possible 55.56 percentage points,
meaning they were at 24% of the range,
giving them a score of two points out of
five for this category.
For the category related to loan
origination market share, there were
two extreme outliers. As a result, we
devised an alternate method to assign
points for this category. The method
used to score this category was to first
put market share values in order from
lowest to highest. Since there were
nineteen banks in the study, the first
three banks received a score of one, the
next four banks received a score of two,
the next five banks received a score of
three, the next four banks received a
score of four, and the final three banks
received a score of five. This was
designed to create a bell curve for this
particular category given the extreme
outliers.
2.12 Acceptance of Alternate
Forms of Identification.
This category was designed to
determine how flexible a bank’s policy
is in accepting alternate forms of
identification when a new customer or
member wishes to open up either a
checking or savings account. If we
could not locate the information on the
bank’s website, a call was placed in an
attempt to ascertain this information.
The specific information that we
obtained was whether or not an
alternate form of identification, defined
as any form of identification other than
a valid passport or state issued
identification, was accepted as either
primary identification or a secondary
form of identification. If there was a
claim that the alternate form was
accepted but we could not confirm this
information through either the website
or telephone call to the bank’s
representative, we concluded that the
bank has a vague policy in that area.
Banks were assigned five points
if they accepted alternate forms of
identification as the primary method of
opening an account. If the policy was
vague as to whether or not they
accepted alternate forms of
identification as a primary method of
opening an account, the bank was
assigned four points. If the bank did
not accept alternate forms of
identification as the primary method,
but did accept alternate forms of
identification as a secondary method of
identification to open an account, the
bank was assigned three points in this
category. If the policy was vague as to
which forms of identification are
acceptable as both primary and
secondary methods of identification,
the bank received a score of two points.
Banks that do not accept alternate
forms of identification at all were given
one point in this category.
2.13 Cost of International Wire
Transfers.
We also chose to analyze and
score the cost of wire transfers.

14
Specifically, we looked at the cost of
outgoing international wire transfers.
We determined this by the type of
transfer more likely to be used by
people in the low- to moderate-income
range. If we could not locate the
information on the bank’s website, a
call was placed in an attempt to
ascertain this information.
The cost of the wire transfers
ranged from $30 to $75 per transfer.
This range was used as the
denominator to determine in which
percentile each bank’s fees fell, (75 –
30). The numerator used was that
particular bank’s (B) fee for outgoing
international wire transfers subtracted
by the lowest value of all of the banks
(B – 30). %= (B – 30) / (75 – 30). Using
this formula, those banks whose fees
were between 0% and 20% were
assigned a score of five points. The
banks whose fees were greater than the
20th percentile and up to and including
40% were assigned a score of four
points. The banks whose fees were
greater than the 40th percentile and up
to and including 60% were assigned a
score of three points. The banks whose
fees were greater than the 60th
percentile and up to and including 80%
were assigned a score of three points.
The banks whose fees were greater
than the 80th percentile and up to and
including 100% were assigned a score
of one point.
2.14 The Appendices and Bank
Responses to Findings.
The data compiled through this
study is available in the appendices.
Appendix A provides an overview of the
scoring system generally. Appendix B
provides the individual findings with
respect to each bank. As mentioned
earlier, all of this information was
shared with each bank assessed for this
study in order for them to confirm or
correct our findings. Where banks
provided specific corrections to our
findings, we incorporated those
corrections into our final results. The
overwhelming majority of the findings
remained uncorrected by the banks.
One bank, JP Morgan Chase, supplied
additional information related to their
products and services but, when asked
to indicate if any of the information we
had gathered was incorrect, did not
identify any such information.

15
3.0 The Ranking of Cumulative Scores.
Once a point value was assigned to each bank under each category, we
compiled a cumulative score for each bank and then ranked the banks according to
this cumulative score. The final score through the NYBRI for 2016 is the following:
Bank
Final Score
First Niagara
75
Citibank
70
M&T
68
JPMorgan Chase
67
Astoria Bank
64
Capital One
64
TrustCo
63
Community Bank
62
KeyBank
60
Citizens Bank
60
Wells Fargo
59
Bank of America
59
NBT
58
Santander
57
HSBC
53
NY Community & Commercial
52
TD Bank
52
Apple Bank
50
People's United
38

16
4.0 Customizing the Bank
Ranking Index.
This report offers New Yorkers
the opportunity to review the products
and services of the nineteen largest
banks servicing individual consumers
throughout the state. In addition to the
scoring and ranking conducted through
this study, individuals can consult the
accompanying website at
www.nybri.org to create a customized
bank ranking. Through that tool,
consumers can identify the categories
that are most important to them and
give them different weights. Following
the prompts on the site, consumers can
then generate a customized ranking
that reflects the products and services
that are the most important to them.
5.0 Conclusion.
The New York Bank Ranking
Index is a tool every New Yorker can
use when making decisions about the
right bank for them. We hope this
study’s findings and the accompanying
website are useful and offer
meaningful and salient guidance to
consumers as they choose the bank
that best fits their needs. In turn, we
hope that the information revealed
through this study will prompt banks
to improve their consumer products
and services. We also hope that other
jurisdictions and communities might
take our methodology and apply it to
banks serving those areas to come up
with their own bank ranking index.
For comments and feedback on
this study and the accompanying
website, please do not hesitate to email
us at NYBRI@gmail.com.

1
Appendix A: General Scoring Rubric

2
Scoring Rubric for NYBRI Categories
Category
5 points
4 points
3 points
2 points
1 point
Number of
Branch
locations
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
Branch
locations:
distribution
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
Online
Banking
Free Apps, Free
Mobile banking,
Free online
banking, "Free"
text banking,
user friendly
All options for 5
points- not user-
friendly
Missing 1
option from 5
points, but
user friendly
Missing 1
option, not
user-friendly
Missing 2
options, not
user-
friendly
Fee for
Outside ATM's
$1 or less
<$2, >$1
$2.00 fee
<$3, >$2
$3 or more
Checking
Account Fees
(basic level or
checkless
checking
account) [3]
5 features
4 features
3 features
2 features
1 feature
Savings
Account Fees
(for the basic
level account)
No minimum
(or nominal
amount of $1),
no monthly fees
regardless of
balance
minimum
amount to open
<$100, fees
waived for avg
monthly balance
of <$500
minimum
amount to open
<$500, fees
waived at avg
monthly
balance of
<$1,000
minimum
amount to open
<$1,000, fees
waived at avg
monthly
balance of
<$2,000
fees waived
at avg
monthly
balance of
$2,000 or
more (or fee
not
waivable)
Overdraft
practices [1]
Meets all “Best
Practices”
standards [1]
Meets 3
Meets 2
Meets 1
Meets 0
Overdraft
Charges and
Limits [2]
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
Credit cards
(basic
secured) (as
compared to
average APR
range)
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20% OR
Does not
offer any
credit cards
Credit Card
Fees
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%

3
Home Mortgage Disclosure Act Categories [4]
Loan Origination
Market Share
(Percentage of
Total Lending
Volume in New
York State)
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
Loan Acceptance
Rate in New York
State
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
Loan Acceptance
Rate, Latino
Borrowers
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
Loan Acceptance
Rate, Black
Borrowers
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
Loan Acceptance
Rate, Low- and
Moderate-Income
Borrowers
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
Percentage of
Loans Made to
Low- and
Moderate-Income
Borrowers
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
Loan Acceptance
Rate, Low- and
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
Acceptance of
alternate
forms of
identification
Accepts
alternate forms
of ID as the
primary
identification
for opening an
account
Claims to accept
alternate forms
of ID for primary
identification,
but policy is
vague
Accepts
alternate forms
of ID as
secondary
identification
to open an
account
Policy is vague
as to what
forms of ID are
acceptable for
both primary
and secondary
methods of
identification
Does not
accept any
alternate
forms of ID
(ONLY
passport
Driver's/Non
driver's ID)
Cost of wire
transfers
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%

4
Moderate-Income
Borrowers
Percentage of
Loans Made to
Communities of
Color
>80% - 100%
>60% - 80%
>40% - 60%
>20% - 40%
0% -20%
[1] These “Best Practices” have been proposed by The Pew Charitable
Trusts, see “Checks and Balances”
http://www.pewtrusts.org/~/media/assets/2015/05/checks_and_balances_rep
ort_final.pdf
These “best practices” are the following:
1. The Fees are clearly disclosed and complete;
2. Cannot opt in to ATM overdrafts;
3. Cannot opt in to POS debit card overdrafts;
4. Order of processing transactions (highest to lowest increases the
overdraft fees).
[2] Limits on overdrafts and amounts charged.
[3] One point is awarded for each of the following features:
1. Number of Transactions: Unlimited;
2. Minimum Opening Deposit $25 or less;
3. Monthly Maintenance Fee If not waivable: $5 or less OR If waivable:
$10 or less; offer at least two options to waive fee with a single
transaction (e.g. direct deposit with no minimum deposit, online bill
pay or debit card purchase);
4. Overdraft or Non-Sufficient Funds (NSF) Fees None, or structurally
not possible (e.g. via checkless checking);
5. Dormancy or Inactivity Fees: None.
[4] For details on how the HMDA mortgage lending was scored, see Section
2.11 in this report.

5
Appendix B: Individual Bank Information and Scores

6
Category
Apple Bank
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) - (74 total
branches).
1
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data)- (22 NY branches
in LMI locations).
5
Online Banking
Free online banking.
1
Fee for Outside ATM's
Fee of $2 charged for using ATM's outside of network.
3
Checking Account Fees
(basic level or checkless
checking account)
Checking (8 Transaction limit, $3 monthly maintenance
charge not waivable, overdraft or NSF charges, no
dormancy or inactivity fee, $10 minimum opening deposit).
3
Savings Account Fees (for
the basic level account)
Savings ($100 minimum to open, $4 fee if balance < $500).
3
Overdraft practices
Basic Checking (Does not reorder high to low, can opt in to
ATM overdrafts, can opt in to POS debit card overdrafts,
fees and practices are not clearly and completely
disclosed).
2
Overdraft Limits and Fees
Overdraft fee is $35 with a limit of 6 charges per day
($210/day).
2
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
15.99% - 22.99%.
3
Credit Card Fees
Monthly late fees can be as high as $37.
2
Acceptance of alternate
forms of identification
Does not accept alternate forms of ID to open account.
1
Cost of wire transfers
Cost of international outgoing wire is $40.
4
Loan Origination Market
Share
.04%
1
Loan Acceptance Rate
39%
2
Loan Acceptance Rate,
Latino Borrowers
25%
2
Loan Acceptance Rate,
Black Borrowers
70%
4
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
15%
1
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
20%
2
Acceptance Rate, Low- and
Moderate-Income
Communities
59%
3
Percentage of Loans Made
to Communities of Color
100%
5
TOTAL
50

7
Category
Astoria Bank
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (85 total NY
branches).
2
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (14 NY
branches in LMI locations).
2
Online Banking
Free Apps, Free mobile banking, Free online
banking.
3
Fee for Outside ATM's
Fee of $2 charged for using ATM's outside of
network.
3
Checking Account Fees
(basic level or checkless
checking account)
Checking (Transaction limit, $3 monthly
maintenance charge waivable if balance > $250,
overdraft or NSF charges, no dormancy or inactivity
fee, $25 minimum opening deposit).
3
Savings Account Fees (for
the basic level account)
Savings ($500 minimum to open, $0 fee).
2
Overdraft practices
Basic Checking (Does not reorder high to low, can opt
in to ATM overdrafts, can opt in to POS debit card
overdrafts, fees and practices are not clearly and
completely disclosed).
2
Overdraft Limits and Fees
Overdraft fee is $35 with a limit of 4 charges per day
($140/day).
4
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
9.99% - 19.99%.
5
Credit Card Fees
Monthly late fees can be as high as $37.
2
Acceptance of alternate
forms of identification
Policy vague as to acceptance of alternate forms of ID
to open account.
2
Cost of wire transfers
Cost of international outgoing wire is $35.
5
Loan Origination Market
Share
1.02
2
Loan Acceptance Rate
75%
4
Loan Acceptance Rate,
Latino Borrowers
73%
4
Loan Acceptance Rate,
Black Borrowers
82%
5
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
89%
5
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
42%
3
Acceptance Rate, Low- and
Moderate-Income
Communities
65%
4
Percentage of Loans Made
to Communities of Color
36%
2
TOTAL
64

8
Category
Bank of America
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (288 total NY
branches).
5
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data)(70 NY
branches in LMI locations).
4
Online Banking
Free Apps, free mobile banking, free online banking,
"free" text banking.
5
Fee for Outside ATM's
Fee of $2.50 charged by Bank of America for using
ATM's outside of network.
2
Checking Account Fees
(basic level or checkless
checking account)
SafeBalance Banking Account: (Unlimited # of
transactions, $4.95 monthly maintenance charge, no
overdraft or NSF charges, no dormancy or inactivity
fees, $25 minimum opening deposit).
5
Savings Account Fees (for
the basic level account)
Savings ($5 fee if you do not maintain a $300
balance- $25 open).
4
Overdraft practices
Core Checking (Reorders some transactions from
highest to lowest, can opt in to ATM overdrafts,
cannot opt in to POS debit card overdrafts, fees and
practices are clearly disclosed).
3
Overdraft Limits and Fees
Overdraft fee is $35 with a limit of 4 per day
($140/day).
4
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
10.99%-22.99%.
4
Credit Card Fees
Monthly late fees can be as high as $37.
2
Acceptance of alternate
forms of identification
Policy vague as to acceptance of alternate forms of ID
to open account.
2
Cost of wire transfers
Cost of international outgoing wire is $45.
4
Loan Origination Market
Share
7.66
4
Loan Acceptance Rate
19%
1
Loan Acceptance Rate,
Latino Borrowers
24%
2
Loan Acceptance Rate,
Black Borrowers
29%
2
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
18%
1
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
22%
2
Acceptance Rate, Low- and
Moderate-Income
Communities
18%
1
Percentage of Loans Made
to Communities of Color
29%
2
TOTAL
59

9
Category
Capital One
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (237 total NY
branches).
4
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (48 NY
branches in LMI locations).
3
Online Banking
Free Apps, free mobile banking, free online banking,
free text banking option.
5
Fee for Outside ATM's
Fee of $0 charged for using ATM's outside of
network.
5
Checking Account Fees
(basic level or checkless
checking account)
360 Checking (No transaction limit, $0 monthly
maintenance charge, NSF charge [$9], no dormancy
or inactivity fee, $0 minimum opening deposit).
4
Savings Account Fees (for
the basic level account)
360 Savings ($0 minimum to open, $0 fee).
5
Overdraft practices
Basic Checking (Reorders some transactions highest
to lowest, cannot opt in to ATM overdrafts, cannot
opt in to POS debit card overdrafts, fees and
practices are clearly and completely disclosed).
4
Overdraft Limits and Fees
NSF fee of $9.
5
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR of
24.99%.
1
Credit Card Fees
Monthly late fees can be as high as $35.
4
Acceptance of alternate
forms of identification
Does not accept alternate forms of ID to open
account.
1
Cost of wire transfers
Cost of international outgoing wire is $40.
4
Loan Origination Market
Share
.94
2
Loan Acceptance Rate
10%
1
Loan Acceptance Rate,
Latino Borrowers
36%
2
Loan Acceptance Rate,
Black Borrowers
33%
2
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
25%
2
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
89%
5
Acceptance Rate, Low- and
Moderate-Income
Communities
21%
2
Percentage of Loans Made
to Communities of Color
49%
3
TOTAL
64

10
Category
Citibank
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (228 total NY
branches).
4
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (57 NY
branches in LMI locations).
4
Online Banking
Free Apps, free mobile banking, free online banking,
free text banking option.
5
Fee for Outside ATM's
Fee of $2.50 charged for using ATM's outside of
network.
2
Checking Account Fees
(basic level or checkless
checking account)
Basic Checking (No transaction limit, $10 monthly
maintenance charge waivable, no overdraft or NSF
charges, no dormancy or inactivity fee, $0 minimum
opening deposit).
5
Savings Account Fees (for
the basic level account)
Savings Plus Account ($100 minimum to open, $12
fee waivable but must be connected to account
package).
2
Overdraft practices
Basic Checking (Does not reorder transactions from
highest to lowest, cannot opt in to ATM overdrafts,
cannot opt in to POS debit card overdrafts, fees and
practices are clearly and completely disclosed).
5
Overdraft Limits and Fees
Overdraft fee is $34 with a limit of 4 per day
($136/day).
4
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
12.99%-21.99%.
4
Credit Card Fees
Monthly late fees can be as high as $35.
4
Acceptance of alternate
forms of identification
Policy is vague as to acceptance of alternate forms of
ID.
2
Cost of wire transfers
Cost of international outgoing wire is $45.
4
Loan Origination Market
Share
16.75
5
Loan Acceptance Rate
62%
4
Loan Acceptance Rate,
Latino Borrowers
57%
3
Loan Acceptance Rate,
Black Borrowers
57%
3
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
48%
3
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
0%
1
Acceptance Rate, Low- and
Moderate-Income
Communities
60%
3
Percentage of Loans Made
to Communities of Color
47%
3
TOTAL
70

11
Category
Citizens Bank
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (142 total NY
branches).
3
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (32 NY
branches in LMI locations).
4
Online Banking
Free apps, free mobile banking, free online banking.
2
Fee for Outside ATM's
Fee of $3 or more charged for using ATM's outside of
network.
1
Checking Account Fees
(basic level or checkless
checking account)
Checking (No transaction limit, $9.99 monthly
maintenance charge waivable, overdraft or NSF
charges, dormancy or inactivity fee, $25 minimum
opening deposit).
3
Savings Account Fees (for
the basic level account)
Savings ($1 minimum to open, $4.99 fee if balance <
$200).
4
Overdraft practices
Basic Checking (Reorders some transactions highest
to lowest, can opt in to ATM overdrafts, can opt in to
POS debit card overdrafts, fees and practices are
clearly and completely disclosed).
2
Overdraft Limits and Fees
Overdraft fee is $35 with a limit of 7 charges per day
($245/day).
1
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
13.99% - 19.99%.
4
Credit Card Fees
Monthly late fees can be as high as $38.
1
Acceptance of alternate
forms of identification
Accepts alternate forms of ID as secondary
identification to open account.
3
Cost of wire transfers
Cost of international outgoing wire is $35.
5
Loan Origination Market
Share
1.87
3
Loan Acceptance Rate
58%
3
Loan Acceptance Rate,
Latino Borrowers
74%
4
Loan Acceptance Rate,
Black Borrowers
72%
4
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
62%
4
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
68%
4
Acceptance Rate, Low- and
Moderate-Income
Communities
64%
4
Percentage of Loans Made
to Communities of Color
14%
1
TOTAL
60

12
Category
Community Bank
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (145 total
NY branches)
3
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (18 NY
branches in LMI locations).
1
Online Banking
Free mobile banking, free online banking.
1
Fee for Outside ATM's
Fee of $2 charged for using ATM's outside of
network.
3
Checking Account Fees
(basic level or checkless
checking account)
Free Checking (No transaction limit, $0 monthly
maintenance charge, overdraft or NSF charges, no
dormancy or inactivity fee, $50 minimum opening
deposit).
2
Savings Account Fees (for
the basic level account)
Free Savings ($0 minimum to open, $0 fee).
5
Overdraft practices
Basic Checking (Reorders some transactions highest
to lowest, can opt in to ATM overdrafts, can opt in to
POS debit card overdrafts, fees and practices are not
clearly and completely disclosed).
1
Overdraft Limits and Fees
Overdraft fee is $32 with a limit of 5 per day
($160/day).
3
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range
of 9.99% - 19.99%.
5
Credit Card Fees
Monthly late fees can be as high as $37.
2
Acceptance of alternate
forms of identification
Policy vague as to acceptance of alternate forms of
ID to open account.
2
Cost of wire transfers
Cost of international outgoing wire is $65.
2
Loan Origination Market
Share
.86
2
Loan Acceptance Rate
91%
5
Loan Acceptance Rate,
Latino Borrowers
76%
4
Loan Acceptance Rate,
Black Borrowers
100%
5
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
86%
5
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
88%
5
Acceptance Rate, Low- and
Moderate-Income
Communities
100%
5
Percentage of Loans Made
to Communities of Color
0%
1
TOTAL
62

13
Category
First Niagara
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (190 branches
in NY).
3
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (48 NY
branches in LMI locations)
4
Online Banking
Free Apps, free Mobile banking, free online banking,
"free" text banking.
2
Fee for Outside ATM's
Fee of $2.50 charged by First Niagara for using
ATM's outside of network.
2
Checking Account Fees
(basic level or checkless
checking account)
First Niagara Simple Checking (No limits on
transactions and a $5 monthly waivable fee, $50
minimum, overdraft fees and an inactive fee of $12).
2
Savings Account Fees (for
the basic level account)
Companion Savings ($4 fee if not waived with a $400
minimum balance, $50 minimum to open account).
4
Overdraft practices
First Niagara Simple Checking (fees are clearly and
completely disclosed but allows opt in to ATM or POS
overdrafts, and reorders some transactions highest to
lowest).
2
Overdraft Limits and Fees
Overdraft fee is $37 with a limit of 5 per day
($185/day).
3
Credit cards (basic
unsecured)
Basic unsecured card has a 14.24% APR.
5
Credit Card Fees
Late fees were capped at $25 per month.
5
Acceptance of alternate
forms of identification
Claims to accept alternate forms of ID for primary
identification, but policy is vague.
4
Cost of wire transfers
Cost of international outgoing wire is $40.
4
Loan Origination Market
Share
2.85
4
Loan Acceptance Rate
87%
5
Loan Acceptance Rate,
Latino Borrowers
88%
5
Loan Acceptance Rate,
Black Borrowers
85%
5
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
93%
5
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
100%
5
Acceptance Rate, Low- and
Moderate-Income
Communities
85%
5
Percentage of Loans Made
to Communities of Color
6%
1
TOTAL
75

14
Category
HSBC
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (145 total NY
branches).
3
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (36 NY
branches in LMI locations)
4
Online Banking
Free Apps, free mobile banking, free online banking,
no text banking option.
2
Fee for Outside ATM's
Fee of $2.50 charged for using ATM's outside of
network.
2
Checking Account Fees
(basic level or checkless
checking account)
Basic Banking Account (8 transaction limit, $3
monthly maintenance charge not waivable, overdraft
or NSF charges, no dormancy or inactivity fees, $0 or
$1 minimum opening deposit).
3
Savings Account Fees (for
the basic level account)
Everyday Savings ($0 fee - $0 or $1 open, limit of 3
transactions if balance < $1,000).
5
Overdraft practices
Core Checking (Does not reorder transactions
highest to lowest, cannot opt in to ATM overdrafts,
cannot opt in to POS debit card overdrafts, fees and
practices are clearly and completely disclosed).
5
Overdraft Limits and Fees
Overdraft fee is $35 with a limit of 3 per day
($105/day).
4
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
12.99%-22.99%.
4
Credit Card Fees
Monthly late fees can be as high as $38.
1
Acceptance of alternate
forms of identification
Accepts alternate forms of ID (for secondary form
only).
3
Cost of wire transfers
Cost of international outgoing wire is $35.
5
Loan Origination Market
Share
3.11%
4
Loan Acceptance Rate
0%
1
Loan Acceptance Rate,
Latino Borrowers
17%
1
Loan Acceptance Rate,
Black Borrowers
16%
1
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
7%
1
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
11%
1
Acceptance Rate, Low- and
Moderate-Income
Communities
2%
1
Percentage of Loans Made
to Communities of Color
39%
2
TOTAL
53

15
Category
JPMorgan Chase
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (758 total NY
branches).
5
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (197 branches
in LMI communities).
4
Online Banking
Free apps, free mobile banking, free online banking,
free text banking option.
5
Fee for Outside ATM's
Fee of $2.50 charged for using ATM's outside of
network.
2
Checking Account Fees
(basic level or checkless
checking account)
Basic Checking (No transaction limit, $12 monthly
maintenance charge waivable, overdraft or NSF
charges, no dormancy or inactivity fee, $25 minimum
opening deposit).
3
Savings Account Fees (for
the basic level account)
Basic Savings ($25 minimum to open, no limit on
transactions, $5 fee waivable if balance > $300).
4
Overdraft practices
Basic Checking (Reorders some transactions highest
to lowest, cannot opt in to ATM overdrafts, can opt in
to POS debit card overdrafts, fees and practices are
clearly and completely disclosed).
3
Overdraft Limits and Fees
Overdraft fee is $34 with a limit of 3 per day
($102/day).
5
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
13.99%-22.99%.
3
Credit Card Fees
Monthly late fees can be as high as $37.
2
Acceptance of alternate
forms of identification
Accepts alternate forms of ID as secondary
identification to open account.
3
Cost of wire transfers
Cost of international outgoing wire is $45.
4
Loan Origination Market
Share
21.09%
5
Loan Acceptance Rate
49%
3
Loan Acceptance Rate,
Latino Borrowers
56%
3
Loan Acceptance Rate,
Black Borrowers
44%
3
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
44%
3
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
19%
1
Acceptance Rate, Low- and
Moderate-Income
Communities
43%
3
Percentage of Loans Made
to Communities of Color
43%
3
TOTAL
67

16
Category
Key Bank
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (228 total NY
branches).
4
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (51 NY
branches in LMI locations)
4
Online Banking
Free apps, free mobile banking, free online banking,
"free" text banking.
4
Fee for Outside ATM's
Fee of $2.50 charged by KeyBank for using ATM's
outside of network.
2
Checking Account Fees
(basic level or checkless
checking account)
KeyBank's Hassle-Free Account (Unlimited number
of transactions, $0 monthly maintenance charge, no
overdraft or NSF charges, no dormancy or inactivity
fees, $10 minimum opening deposit).
5
Savings Account Fees (for
the basic level account)
Key Saver Personal Savings ($4 fee if you do not
maintain a $300 balance- $50 open).
4
Overdraft practices
Key Express Checking Account (Does not reorder
from highest to lowest, can opt in to ATM overdrafts,
can opt in to POS debit card overdrafts, fees are not
clearly disclosed and complete).
2
Overdraft Limits and Fees
KeyBank charges $34 for the first 2 overdrafts and
$38.50 for any above that with a cap of 20 charges
per month.
1
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
10.99%-20.99%.
5
Credit Card Fees
Monthly late fees can be as high as $35.
4
Acceptance of alternate
forms of identification
Does not accept any alternate forms of ID (ONLY
passport Driver's/Non driver's ID, as per KeyBank's
customer representative and disclosure booklet).
1
Cost of wire transfers
Cost of international outgoing wire is $45.
4
Loan Origination Market
Share
1.03%
3
Loan Acceptance Rate
29%
2
Loan Acceptance Rate,
Latino Borrowers
49%
3
Loan Acceptance Rate,
Black Borrowers
38%
2
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
33%
2
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
84%
5
Acceptance Rate, Low- and
Moderate-Income
Communities
34%
2
Percentage of Loans Made
to Communities of Color
8%
1
TOTAL
60

17
Category
M&T
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (273 total NY
branches).
5
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (57 NY
branches in LMI locations)
3
Online Banking
Free mobile banking, free online banking.
2
Fee for Outside ATM's
Fee of $3 charged for using ATM's outside of
network.
1
Checking Account Fees
(basic level or checkless
checking account)
EZ Choice Checking (No transaction limit, $6.95
monthly maintenance charge waivable, no overdraft
or NSF charges, no dormancy or inactivity fee, $0
minimum opening deposit.
5
Savings Account Fees (for
the basic level account)
Savings ($0 minimum to open, $15 fee if balance <
$2,500).
1
Overdraft practices
Basic Checking (Does reorder from highest to lowest,
can opt in to ATM overdrafts, can opt in to POS debit
card overdrafts, fees and practices are not clearly and
completely disclosed).
1
Overdraft Limits and Fees
Overdraft fee is $38.50 with a limit of 5 per day
($192.50/day).
2
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
10.24% - 17.24%.
5
Credit Card Fees
Monthly late fees can be as high as $35.
4
Acceptance of alternate
forms of identification
Does not accept alternate forms of ID to open
account.
1
Cost of wire transfers
Cost of international outgoing wire is $75.
3
Loan Origination Market
Share
3.93%
4
Loan Acceptance Rate
100%
5
Loan Acceptance Rate,
Latino Borrowers
100%
5
Loan Acceptance Rate,
Black Borrowers
100%
5
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
100%
5
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
100%
5
Acceptance Rate, Low- and
Moderate-Income
Communities
96%
5
Percentage of Loans Made
to Communities of Color
16%
1
TOTAL
68

18
Category
NBT Bank
Score
Number of Branch locations
Data obtained from NCRC (2015 Data)- (107 total
NY branches)
2
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (19 NY
branches in LMI locations).
2
Online Banking
Free Apps, free mobile banking, free online banking,
free text banking.
5
Fee for Outside ATM's
Fee of $1 or less charged for using ATM's outside of
network.
5
Checking Account Fees
(basic level or checkless
checking account)
Checking (No transaction limit, $0 monthly
maintenance charge, overdraft or NSF charges, no
dormancy or inactivity fee, $0 minimum opening
deposit).
4
Savings Account Fees (for
the basic level account)
Savings ($0 minimum to open, $0 fee).
5
Overdraft practices
Basic Checking (Reorders some transactions highest
to lowest, can opt in to ATM overdrafts, can opt in to
POS debit card overdrafts, fees and practices are not
clearly and completely disclosed).
1
Overdraft Limits and Fees
Overdraft fee is $32 with a limit of 6 charges per day
($192/day).
2
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
9.99% - 20.99%.
5
Credit Card Fees
Monthly late fees can be as high as $38.
1
Acceptance of alternate
forms of identification
Does not accept alternate forms of ID to open
account.
1
Cost of wire transfers
Cost of international outgoing wire is $50.
3
Loan Origination Market
Share
.67%
1
Loan Acceptance Rate
57%
3
Loan Acceptance Rate,
Latino Borrowers
63%
4
Loan Acceptance Rate,
Black Borrowers
90%
5
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
46%
3
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
58%
3
Acceptance Rate, Low- and
Moderate-Income
Communities
33%
2
Percentage of Loans Made
to Communities of Color
.6%
1
TOTAL
58

19
Category
NY Community and Commercial
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (155 total NY
branches).
3
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (30 NY
branches in LMI locations)
3
Online Banking
Free mobile banking, free online banking.
1
Fee for Outside ATM's
Fee of $2.50 charged for using ATM's outside of
network.
2
Checking Account Fees
(basic level or checkless
checking account)
Checking (No transaction limit, $0 monthly
maintenance charge, overdraft or NSF charges, no
dormancy or inactivity fee, $1 minimum opening
deposit).
4
Savings Account Fees (for
the basic level account)
Savings ($100 minimum to open, $5 fee if balance <
$500).
3
Overdraft practices
Basic Checking (Does not reorder from highest to
lowest, can opt in to ATM overdrafts, can opt in to
POS debit card overdrafts, fees and practices are not
clearly and completely disclosed).
2
Overdraft Limits and Fees
Overdraft fee is $36 with a limit of four fees per day.
However, there is no limit on the consecutive days
these fees can be incurred.
1
Credit cards (basic
unsecured)
The basic unsecured credit card has an APR range
from 16.24%-23.24%
3
Credit Card Fees
Monthly late fees can be as high as $37.
2
Acceptance of alternate
forms of identification
Does not accept alternate forms of ID to open
account.
1
Cost of wire transfers
Cost of international outgoing wire is $50.
3
Loan Origination Market
Share
.72
2
Loan Acceptance Rate
70%
4
Loan Acceptance Rate,
Latino Borrowers
79%
4
Loan Acceptance Rate,
Black Borrowers
69%
4
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
66%
4
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
5%
1
Acceptance Rate, Low- and
Moderate-Income
Communities
51%
3
Percentage of Loans Made
to Communities of Color
21%
2
TOTAL
52

20
Category
People’s United
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (98 total NY
branches).
2
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (13 NY
branches in LMI locations).
1
Online Banking
(Free online banking, free mobile banking).
1
Fee for Outside ATM's
Fee of $3 charged for using ATM's outside of
network.
1
Checking Account Fees
(basic level or checkless
checking account)
Checking (No transaction limit, $0 monthly
maintenance charge, overdraft or NSF charges, no
dormancy or inactivity fee, $25 minimum opening
deposit).
3
Savings Account Fees (for
the basic level account)
Savings ($50 minimum to open, $5 fee if balance <
$250).
4
Overdraft practices
Basic Checking (Does not reorder from highest to
lowest, can opt in to ATM overdrafts, can opt in to
POS debit card overdrafts, fees and practices are
clearly and completely disclosed).
3
Overdraft Limits and Fees
Overdraft fee is $37 with a limit of 5 charges per day
($185/day).
3
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
9.99% - 20.99%.
5
Credit Card Fees
Monthly late fees can be as high as $38.
1
Acceptance of alternate
forms of identification
Policy vague as to acceptance of alternate forms of ID
to open account.
2
Cost of wire transfers
Cost of international outgoing wire is $40.
4
Loan Origination Market
Share
.42
1
Loan Acceptance Rate
5%
1
Loan Acceptance Rate,
Latino Borrowers
0%
1
Loan Acceptance Rate,
Black Borrowers
0%
1
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
0%
1
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
.6%
1
Acceptance Rate, Low- and
Moderate-Income
Communities
0%
1
Percentage of Loans Made
to Communities of Color
19%
1
TOTAL
38

21
Category
Santander
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (73 total NY
branches).
1
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (14 NY
branches in LMI locations).
3
Online Banking
Free apps, free online banking, no text banking
option.
1
Fee for Outside ATM's
Fee of $3 charged for using ATM's outside of
network.
1
Checking Account Fees
(basic level or checkless
checking account)
Basic Checking (No transaction limit, $3 monthly
maintenance charge not waivable, overdraft or NSF
charges, dormancy or inactivity fee, $25 minimum
opening deposit).
3
Savings Account Fees (for
the basic level account)
Basic Savings ($25 minimum to open, no limit on
transactions, $1 if balance < $100).
3
Overdraft practices
Basic Checking (Does not reorder from highest to
lowest, can opt in to ATM overdrafts, can opt in to
POS debit card overdrafts, fees and practices are
clearly and completely disclosed).
3
Overdraft Limits and Fees
Overdraft fee is $35 with a limit of 4 per day
($140/day).
4
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
15.99%-24.99%.
3
Credit Card Fees
Monthly late fees can be as high as $35.
4
Acceptance of alternate
forms of identification
Policy vague as to acceptance of alternate forms of
ID.
2
Cost of wire transfers
Cost of international outgoing wire is $40.
4
Loan Origination Market
Share
2.02
3
Loan Acceptance Rate
74%
4
Loan Acceptance Rate,
Latino Borrowers
67%
4
Loan Acceptance Rate,
Black Borrowers
72%
4
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
58%
3
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
1%
1
Acceptance Rate, Low- and
Moderate-Income
Communities
63%
4
Percentage of Loans Made
to Communities of Color
38%
2
TOTAL
57

22
Category
TD Bank
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (236 total NY
branches).
4
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (42 NY
branches in LMI locations).
2
Online Banking
Free apps, free mobile banking, free online banking.
3
Fee for Outside ATM's
Fee of $3 charged for using ATM's outside of
network.
1
Checking Account Fees
(basic level or checkless
checking account)
Simple Checking (No transaction limit, $5.99
monthly maintenance charge not waivable, overdraft
or NSF charges, no dormancy or inactivity fee, $0
minimum opening deposit).
3
Savings Account Fees (for
the basic level account)
Simple Savings ($0 minimum to open, $5 fee if
balance < $300).
4
Overdraft practices
Basic Checking (Does not reorder from highest to
lowest, can opt in to ATM overdrafts, can opt in to
POS debit card overdrafts, fees and practices are
clearly and completely disclosed).
3
Overdraft Limits and Fees
Overdraft fee is $35 with a limit of 5 per day
($175/day).
3
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
12.99% - 22.99%.
4
Credit Card Fees
Monthly late fees can be as high as $35.
4
Acceptance of alternate
forms of identification
Policy vague as to acceptance of alternate forms of ID
to open account.
2
Cost of wire transfers
Cost of international outgoing wire is $75.
4
Loan Origination Market
Share
2.44
3
Loan Acceptance Rate
21%
2
Loan Acceptance Rate,
Latino Borrowers
25%
2
Loan Acceptance Rate,
Black Borrowers
32%
2
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
6%
1
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
4%
1
Acceptance Rate, Low- and
Moderate-Income
Communities
22%
2
Percentage of Loans Made
to Communities of Color
37%
2
TOTAL
52

23
Category
TrustCo Bank
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (236 total NY
branches).
2
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (42 NY
branches in LMI locations).
2
Online Banking
Free apps, free mobile banking, free online banking.
1
Fee for Outside ATM's
Fee of $3 charged for using ATM's outside of
network.
3
Checking Account Fees
(basic level or checkless
checking account)
Simple Checking (No transaction limit, $5.99
monthly maintenance charge not waivable, overdraft
or NSF charges, no dormancy or inactivity fee, $0
minimum opening deposit).
3
Savings Account Fees (for
the basic level account)
Simple Savings ($0 minimum to open, $5 fee if
balance < $300).
4
Overdraft practices
Basic Checking (does not post from lowest to highest,
can opt in to ATM overdrafts, can opt in to POS debit
card overdrafts, fees and practices are not clearly and
completely disclosed).
1
Overdraft Limits and Fees
Overdraft fee is $35 with a limit of 5 per day
($175/day).
4
Credit cards (basic
unsecured)
The basic unsecured credit card had an APR range of
12.99% - 22.99%.
5
Credit Card Fees
Monthly late fees can be as high as $35.
3
Acceptance of alternate
forms of identification
Policy vague as to acceptance of alternate forms of ID
to open account.
5
Cost of wire transfers
Cost of international outgoing wire is $75.
4
Loan Origination Market
Share
1.87
3
Loan Acceptance Rate
75%
4
Loan Acceptance Rate,
Latino Borrowers
85%
5
Loan Acceptance Rate,
Black Borrowers
59%
3
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
60%
4
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
22%
2
Acceptance Rate, Low- and
Moderate-Income
Communities
64%
4
Percentage of Loans Made
to Communities of Color
7%
1
TOTAL
63

24
Category
Wells Fargo
Score
Number of Branch locations
Data obtained from NCRC (2015 Data) (83 total NY
branches).
1
Branch Locations:
Distribution in LMI
Communities
Data obtained from NCRC (2015 Data) (9 NY
branches in LMI locations).
1
Online Banking
Free app, free mobile banking, free online banking,
free text banking.
2
Fee for Outside ATM's
Fee of $2.50 charged for using ATM's outside of
network.
2
Checking Account Fees
(basic level or checkless
checking account)
Checking (No transaction limit, $10 monthly
maintenance charge waivable, overdraft or NSF
charges, no dormancy or inactivity fee, $25 minimum
opening deposit for online opening).
4
Savings Account Fees (for
the basic level account)
Savings ($25 minimum to open, $5 monthly fee if
balance < $300).
4
Overdraft practices
Basic Checking (Does not reorder highest to lowest,
can opt in to ATM overdrafts, can opt in to POS debit
card overdrafts, fees and practices are clearly and
completely disclosed).
3
Overdraft Limits and Fees
Overdraft fee is $35 with limit of 4 charges per day
($140/day).
4
Credit cards (basic
unsecured)
The basic unsecured credit card has an APR range
from 15.4%-25.24%
3
Credit Card Fees
Monthly late fees can be as high as $37.
2
Acceptance of alternate
forms of identification
Policy is vague as to acceptance of alternate forms of
ID.
2
Cost of wire transfers
Cost of international outgoing wire is $30.
5
Loan Origination Market
Share
32.58%
5
Loan Acceptance Rate
62%
4
Loan Acceptance Rate,
Latino Borrowers
66%
4
Loan Acceptance Rate,
Black Borrowers
63%
4
Loan Acceptance Rate, Low-
and Moderate-Income
Borrowers
47%
3
Percentage of Loans Made
to Low- and Moderate-
Income Borrowers
2%
1
Acceptance Rate, Low- and
Moderate-Income
Communities
55%
3
Percentage of Loans Made
to Communities of Color
32%
2
TOTAL
59

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