§__.24(d)(3) – 2
Q: Are debit cards considered under the service test as an alternative delivery system?
A2. By themselves, no. However, if debit cards are a part of a larger combination of products, such as a comprehensive electronic banking service, that allows an institution to deliver needed services to low- and moderate-income areas and individuals in its community, the overall delivery system that includes the debit card feature would be considered an alternative delivery system.
Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016