Unlike the SafeStart account, Bank On doesn't set clear standards, offering only guidelines for limiting fees and improving access, which increases bank participation at the expense of riskier accounts. Financial education isn't a mandatory part of the program, either.

When Dallas established goals for its Bank On program in August 2009, it aimed to increase the supply of starter bank accounts, raise awareness of the potential benefits of mainstream banking, provide second chance accounts, and encourage financial education and asset building.

And the designer of the plan outlined lessons learned from other cities, including:

• Early buy-in from financial institutions
• City staffing and leadership
• Involvement with community organizations and employers
• Marketing support

Since then, the city has secured support from most of the region’s top banks, launched a campaign from City Hall, formed partnerships with community organizations, and developed plans to market the campaign to low-income households and Spanish speakers through fliers from schools and on water and electricity bills.

But while Bank On accounts will have no or low monthly fees and no minimum balance requirement, they did not secure guaranteed overdraft fee waivers, free checks, or second chance accounts for people who have had problems in the past. And like San Francisco, financial literacy training is not required for participation in the program.

Fernholz uses the New York Department of Consumer Affairs and its Office of Financial Empowerment as models for national replication under the Consumer Financial Protection Agency. But as he noted, the bills in Congress don’t allow for the CFPA to create a “plain vanilla” product. In the absence of that, cities will need to continue to pick up the slack and work with banks and credit unions and community organizations to reach into unbanked communities, especially considering a large percentage of these communities remain in urban areas.