My name is Lesley Williams from the Community Alliance for Better Government, and I am speaking in support of Ordinance 2-O-23, the proposed ban on cashless businesses in Evanston. Although there are not many in Evanston, this is a growing trend with serious implications for low income, disabled and unbanked citizens. Requiring that all businesses serve customers who use cash is clearly an equity issue.
Cashless businesses have been banned in Philadelphia, San Francisco, New York City and the states of Massachusetts, New Jersey, and Rhode Island. They are opposed as discriminatory by both the ACLU and the NAACP.
The sponsor of the New York ordinance stated that “a cashless business model is an expression of institutionalized racism insofar as it disproportionately excludes people of color,” who tend to have less access to credit and debit and therefore have a diminished ability to purchase goods and services in an increasingly cashless marketplace. A cashless business model, however well-intentioned, could have a discriminatory effect on the underbanked and unbanked, on immigrants who have no documentation, on homeless people who have no permanent address, and on communities of color that live in poverty.”
While I appreciate the challenges faced by small businesses, and concerns about theft, there is little evidence that allowing cash transactions will significantly increase security risks. On the other hand, requiring patrons to use electronic payments exposes users to security risks which they should not be forced to accept.
Given Evanston’s stated goals of eliminating institutional racism and promoting racial and social equity, CABG enthusiastically supports this proposal.
I’m sharing below a statement from New Jersey Citizen Action explaining why the state passed a similar law in 2019. Philadelphia, New York City and San Francisco also ban cashless businesses.
STATEMENT OF BEVERLY BROWN RUGGIA, DIRECTOR, FINANCIAL JUSTICE PROGRAM, NEW JERSEY CITIZEN ACTION
My name is Beverly Brown Ruggia, and I am the financial justice director for New Jersey Citizen Action, a Statewide nonprofit organization which has been working since 1984 for social, racial, and economic justice through advocacy, organizing, and community empowerment programs for low- and moderate-income New Jerseyans.
In 2019, New Jersey passed bipartisan legislation to
protect consumer choice to use cash as payment for most
retail purchases. The legislature acted because denying cash as
a form of payment for goods and services discriminates against
people who cannot afford or are unable to obtain noncash
payment options. Additionally, the practice potentially
subjects consumers to unnecessary costs, violations of privacy,
and to cybersecurity risks.
Cashless payment policies discriminate against communities
of color and low-income customers disproportionately. As has
been cited, the FDIC showed that 7.1 million Americans are
unbanked or live in households where no one has a bank account.
According to the study, almost 15 percent of African-American
households and about 13 percent of Latino households are
unbanked, compared with just 2 to 3 percent of White
households.
Another 24 million households are underbanked, meaning that
at least one household member has a bank account but does not
generally use credit cards or other traditional bank credit
products. Indigenous and working-age disabled households and
households with volatile income are also among the unbanked and underbanked at high rates.
A 2018 Reveal news report demonstrated that redlining
persists in this country and still denies millions of low- and
moderate-income people, especially Black and Brown people,
access to banking services and accounts. Even where possible,
opening a bank account requires documents, which many low-
income and elderly people do not have. People experiencing
homelessness usually cannot provide utility bills or other
proof of address needed to open a bank account.
Online banking services also require, as has been said,
reliable and affordable internet access, which low- and fixed-
income people often cannot afford, and people for whom English
is not their first language are more likely to be unbanked than
native English speakers.
But the main reason cited by 29 percent of the FDIC
survey’s respondents is not having enough money to maintain the minimum balances required to open and maintain a bank account.
Cashless policies specifically penalize individuals and
households who cannot afford a bank account, a credit card, and
the consumer credit products needed to make noncash payments.
The alternatives to credit cards, such as prepaid cards or
mobile devices, are costly. A study by the Financial Health
Network found that in 2018, unbanked and underbanked households spent $180 billion in fees and interest on nonbank financial products.
Cashless payment policies can also pose practical barriers.
One of Citizen Action’s Board Co-Chairs is blind. She cannot
use bank cards because the terminals are not accessible in
design, lacking braille key pads and appropriate PIN security,
for example. In other words, cashless policies exclude the
most-vulnerable individuals and households among us who are not able or cannot afford to use anything but cash.
The second-most popular reason cited in the FDIC survey of
unbanked households was a distrust of the banking system. Bank
card payments are not as private as cash payments. Point of
sale systems give businesses and large companies access to
personal and financial information. Cashless payments also
force customers to expose themselves to potential identity
theft and other forms of cyber fraud.
So, it should be no surprise that another national study
found that cash has been the preferred method for daily
transactions among communities of color, whether they are
banked or unbanked.
Technology in banking and finance must expand financial
equity and inclusion by providing choices and options that make
personal financial management easier, more efficient, and safer
for all consumers. Technology must not limit choices and
perpetuate systemic inequities in our financial system that
exclude and discriminate.
Cashless payment policies amount to discriminatory retail
redlining. Instead of a redline around a neighborhood, there
are millions of redlines around individual customers shopping
on Main Street every day which deny them access to goods and
services despite having perfectly sufficient U.S. legal tender
to spend.
Thank you.
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