The Clarity Statement [endnote 8] can be reached through links on the Bank of American website, and only recently as a link from Google. Apparently, the Clarity Statement—for credit cards, checking or both (I’m not sure)—were first issued in late 2009.

Much of this tells us what we already know from the website, though it does make explicit the new rates of penalization for overdrafts. These are “new” rates brought on by recent pressures from customers and the government in this time of recession. To this extent, the “Clarity Statement” can be seen as an advertisement, but also as a useful warning. I don’t remember receiving one in the mail.

The key paragraph in this document is the following, which to my knowledge doesn’t appear anywhere on the website:

“We encourage you to record all your transactions in a check register. This can help you keep track of your account balance and avoid overdrafts. Please note that the account balance that we show you may not include all of your pending transactions, such as a check you have written but which we have not received.”

The emphasis on the website—in blaring advertisements, talking Flash women in comfortable slacks, in images of happy fathers toting their children, in appeals to green sensibilities, and finally in calls to do banking on your mobile phones—is that banking with BoA can, and even should, be paperless. That the bank would suggest using a check register—who uses checks anymore?—in its Clarity Statement is a joke.

In calls that I’ve made in the past to the Bank of America concerning my overdraft fees, eventually the person at customer service will roll out the line with these very same words, “The Bank of America encourages you to…” Part of my motivation for this exhaustive analysis of the website is to show how hypocritical it is that customer service, and now the “Clarity Statement,” would try emphasize the inadequacies of their own customers in dealing with their product (and by product, I mean the Online Banking site, which—like the downloadable application available for iPhone [endnote 9]—is a piece of software).

A news story [endnote 10] on the Clarity Statement reported the following: “Our goal [with the Clarity State-ment] is to communicate clearly and make it as simple and easy to understand as possible so that they can use credit wisely,” Ric Struthers, president of the bank’s Global Card Services division, said.” I am not sure why a single sheet of paper is need to, or even could, explain the workings of huge website, and if clarity is so important, why doesn’t the Clarity Statement appear on the first page of the site?

Consequently, a link to the Clarity Statement—an actual webpage this time, but one that is not open to being Googled because it is behind the firewall—does come up on a search of the BoA site. The link is found at the very bottom of a page called “Fees at a Glance,” which like the other pages that offer fee information, is largely devoid of it. It is in a section with links about “more detailed information about your accounts.” The Clarity Statement doesn’t have any more detailed information in it. The sentence concerning keeping a personal register—paper or electronic—is unique to this hard to reach document, and contradicts everything else the website is telling you to do.

I am not wise enough to know whether the Clarity Statement has been created to help the bank avoid lawsuits down the line—they could always point to it and say “we told you!”—but I somehow doubt it. Nonetheless, it’s no help to users of the website. Consequently, most people under thirty have probably never written a check, and to tell them now to keep a checkbook to keep track of every little transaction on their debit cards is absurd.

This post is a section of Bank of America Online Banking: A Critical Evaluation. This essay is also available as a book which can be downloaded for free at Lulu (where an inexpensive, not-priced-for-profit print edition can also be purchased) and at Scribd. The table of contents for the blog version of this essay can be seen in its entirety here.