But that bank does clever verification – using social media, Google, Google Earth (does the claimed home address exist?) – to attempt to dig deeply into who its customers are. “It's amazing what you can find out,” said Dickson.

Her bank also takes a photograph of every new account applicant and uses sophisticated tools to match the face with identity.

A continuing focus at both institutions is money laundering – it is not always easy to verify sources of funds – and that is a reason why Franklin stressed, several times, “talk early and often with your regulator.”

Her experience is that regulators can be made comfortable about serving these populations but a key is regular conversation and listening to their concerns.

Both institutions attempt to provide continuing financial education to these groups, the panelists told the Tuesday session at the Phoenix conference.

As for the risks in serving them, Dickson said: “Risk? What risk? To us, this is normal business and we follow normal safety and soundness steps.”

She added, “Don't be afraid to enter this market. Everybody deserves a banking relationship and these are good customers.”