Bank of America and know-your-customer

Financial institutions in the US are subject to know-your-customer regulations which requires them to verify the identity of customers. These rules are designed to identify money-laundering and terrorist network financing operations; in fact some provisions derive from the PATRIOT act.  This is one reason opening a bank account requires government issued ID and social-security number. Virgin Islands or Switzerland may be portrayed as havens for  hear-no-evil, no-name private banking in the average Hollywood crime caper. The strict banking regulations make it unlikely they will be opening a US branch anytime soon.

But when it comes to a more basic notion of knowing the customer– such as having a clue about them  before mailing out credit card offers– it turns out the banks could use some help. “Usted ha sido previamente calificado para una tarjeta de credito que podria ahorrarle dinero.” says the message visible in the envelope. Not a Spanish speaker? Neither is this blogger but that would not stop Bank of America from sending an unsolicited, pre-approved credit card offer in Spanish. Twice.

In fairness, after opening the envelope it turned out to be bilingual: there were two copies. That is a good thing: from New York subways to product manuals, there are good signs that institutions are adjusting to the reality of a diverse America. More importantly both versions appeared to offer the same basic terms: it would have been blatant discrimination if the APR were higher on the Spanish offer for example. It is a small error, but indicative of the impersonal nature of credit. One would expect that with a cottage industry in consumer data-mining and extensive dossiers compiled on all US residents, a bank would be able to determine the primary language of a customer they are trying to solicit business from. BoA, or more precisely the random company where they outsourced the credit-card offer carpet bombing operation, did make a decision in putting one of the two variants first, visible in the envelope window. From their point of view the recipient is not a person with a language preference but a one-dimensional statistic, reduced to the FICO score.


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