
Regulators' decision to crack down on such practices as the $35 overdraft fees will result in higher prices for other services, further increasing the number of customers who cannot afford banking services.
"The most regrettable unintended consequence of some of the quickly written regulatory reform, we believe, will be the inevitable 'de-banking' of the U.S. financial system," she writes.
In January 2009, a Federal Deposit Insurance Corp. survey found that 30 million U.S. households were "unbanked" or "underbanked" -- that is, they did not have accounts at banks or other mainstream financial institutions, despite FDIC efforts to encourage banks to expand their low-cost offerings.
Whitney expects the ranks of the "unbanked" will rise to 41 million households in 2015, as institutions reconsider the costs and benefits of all manner of products.
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