We are contemplating a checking account product for those persons who show up on Chex Systems and otherwise wouldn't qualify for a regular checking account. Would we be able to ask the customers' gross annual income so that we could determine how many Low and moderate individuals we are servicing with this product? Any thoughts would be appreciated. thanks

Not 100% sure of my answer, but I would think this product will give you credit under the Service Test, and that there would be nothing gained by collecting income info, even if it were permissable. I think the examiners will view the account as a logical way for you to serve customers in the spirit of CRA, but will just be an added bullet point to your list of services offered.

Just my opinion.

As Chex Systems is not an indicator of Low or Mod, If the account is geared towards low and mod individuals (if credit counseling is involved, you would get credit for community development service) then "CubDave" is correct IMO it will add an additional bullet on the services offered. IMO