CFPB director Richard Cordray signaled a more comprehensive approach to regulating bank operations at a forum on access to checking accounts earlier this month. Cordray focused on how financial institutions may use specialty credit scores to bar risky customers from opening accounts, or to target customers who are most likely to use overdraft protection as a credit product. Cordray criticized specialty consumer reporting agencies, which collect databases of “derogatory” information on customers, including how many times a consumer overdrew their account. Although the CFPB has raised these concerns individually in the past, the speech marks the first time the regulator has taken a system-wide dive into how banks operate rather than as part of remarks on the underbanked or underserved.