Building Customer Loyalty in Financial Services
In financial services, loyalty rests on trust and the depth of the relationship, not points alone. Here is how to build it responsibly.
Last updated October 2026
Table of Contents

Introduction
A financial services loyalty program is a program a bank, credit union, card issuer, insurer, wealth firm or fintech runs to deepen customer relationships, recognizing customers for the breadth, tenure and health of their relationship with the institution rather than for single transactions alone. Card points, cashback and miles are the familiar version. The broader opportunity is to give customers reasons to bring more of their financial lives to one institution and stay.
Research from Gallup's retail banking studies suggests why depth and trust matter. The figures are older and show associations rather than proof of cause, but they point the same way:
|
What the research shows |
Finding |
Source |
|---|---|---|
|
Fully engaged customers stay longer |
Their attrition rate is 50% lower than that of actively disengaged customers |
Gallup, 2015 |
|
Fully engaged customers are worth more |
They bring 37% more annual revenue to their primary bank than actively disengaged customers |
Gallup, 2015 |
|
Financial well-being and engagement go together |
When customers strongly agree that their bank looks out for their financial well-being, 84% are fully engaged |
Gallup, 2015 |
|
Few customers feel that support |
Only one in four customers strongly agree that their bank looks out for their financial well-being |
Gallup, 2015 |
Gallup's revenue and attrition figures come from panel studies run in 2011 and 2014, and its well-being findings from a November 2013 survey, so treat them as direction rather than current benchmarks. The figures compare the most and least engaged groups, which widens the gaps, and the direction can run both ways: customers who already bank mainly with an institution may report higher engagement because of that relationship, not only stay because they are engaged.
One principle runs through this guide: a financial loyalty program should never reward customers into behavior that harms their financial health. Deepening a relationship is a legitimate goal; rewarding unsuitable products, over-borrowing or over-trading is not. Financial services is heavily regulated, and the rules differ by product and line of business, so this guide is general information, not legal advice.
Why Financial Services Loyalty Is Different
Three things set financial services apart from most loyalty categories.
- Trust carries the relationship. A customer hands an institution their savings, debts and financial data. A rewards program layered over fees the customer did not expect, or over terms that change without notice, can cost more trust than the rewards earn back.
- Card rewards are common. Points, cashback and miles are widespread in cards, so a rate alone is easy to match. In a May 2024 report, the CFPB said it analyzed "several hundred consumer complaints" about credit card rewards and found four recurring themes: "unexpected promotional conditions," "devaluation," "redemption problems" and "revocation." Rewards that are hard to earn or that lose value can damage the relationship they were meant to build.
- The institution can influence financial decisions. A bank or broker can shape how customers borrow, save and invest, so a program has to avoid rewarding behavior that is not in the customer's interest.
The posts on why points alone no longer build financial loyalty and the economics of financial loyalty programs cover card and bank program economics in more depth.
Reward the Relationship
Most financial loyalty programs reward products in isolation: points on the card, a bonus on the checking account, a rate on savings. Customers with several products, longer tenure and regular engagement can be worth more over time, so a program can recognize the whole relationship instead.
|
Reward this |
Not only this |
To build |
|---|---|---|
|
Relationship depth and tenure |
The latest transaction |
A primary-institution relationship |
|
Holding several products that suit the customer |
Points on a single card |
Share of wallet and retention |
|
Healthy financial actions |
Spend alone |
Trust and better financial habits |
|
Digital adoption alongside access to people |
Branch-only interaction |
Lower cost to serve without losing engagement |
|
Referrals |
Paid acquisition alone |
Growth from trust |
Digital adoption needs care. The same Gallup research found that branches drive engagement more than online or mobile channels, and that customers who moved from branch to mobile banking were less engaged, so reward digital use without cutting customers off from people when they need them.
Three design choices make relationship rewards work:
- Define primacy. Decide what counts as a primary relationship, for example direct deposit plus a minimum number of products or active months, and make the definition visible to customers so they know how to qualify. Count only products that are funded and used, keep employee sales incentives separate from customer product-count rewards, and avoid tier rules that push customers to apply for credit they do not need.
- Use tiers customers can reach. Relationship tiers with clear thresholds, such as fee waivers, better rates or service levels, give customers a reason to consolidate. Customers tend to put in more effort as a threshold comes into view (the goal-gradient effect, shown in loyalty programs by Kivetz, Urminsky and Zheng), and once they hold a tier, the prospect of losing its benefits may give them a reason to stay (an application of loss aversion, from Kahneman and Tversky's work). The same effect cuts the other way, since a customer who drops a tier can feel the loss sharply and disengage, so show progress toward the next tier and give notice and a grace period before a customer drops one. The guide to tiered loyalty programs covers setting thresholds.
- Bring the data together. Products often sit in separate systems, so a relationship view needs a single customer record across deposits, cards, loans and investments before rewards can recognize the whole relationship. Because the program will handle customer and transaction data, put any rewards platform through the same vendor due diligence as other providers that touch customer data: security attestations, access controls and how data moves to rewards partners. Brandmovers holds SOC 2 Type II and PCI DSS.
In BLOYL™, Brandmovers' loyalty platform, a primacy definition like this can be set as earning rules by customer segment, behavioral action and time window, within tiered or hybrid structures, with bidirectional CRM and CDP data flows carrying the relationship view into the program.
Relationship rewards have a fairness question built in. Rewards based on balances or product count tend to favor wealthier customers, so check how tiers and offers land across customer groups, and give customers with smaller balances a path to recognition through actions such as regular saving or digital engagement.
Rewards that have been earned but not redeemed are a cost the institution carries until customers use them or they expire, so budget to expected redemption, not to points issued. A high unredeemed share can look like a saving on the books, but it can also mean customers find rewards hard to use, which is one of the redemption problems the CFPB found in rewards complaints. Cutting the value of points already earned to reduce that cost is the devaluation the CFPB's Circular 2024-07 warns credit card issuers against, and a risk for any program, so set expiry and redemption terms at launch and change them only with notice.
Build on Trust and Financial Well-Being
The Gallup findings suggest that customers who feel their institution looks out for their financial well-being are more engaged. Gallup did not test whether rewards create that feeling, so treat well-being rewards as a hypothesis to measure against a holdout. A program can make that support concrete by rewarding the actions that improve a customer's position.
- Reward completed actions, not clicks. Points for opening a budgeting tool are easy to collect without changing anything. Rewards for an automatic savings transfer kept for three months, a paid-down balance or an emergency fund that reaches a set amount reward the behavior itself.
- Make education useful. Short, relevant guidance at decision points, such as before a first mortgage or a large purchase, is a better bet than a library of modules customers click through for points, which rewards completion rather than learning.
- Keep the line clear. Reward actions that help the customer, and never tie rewards to borrowing more, carrying a balance or trading more often.
- Use data with consent. Well-being features rely on transaction data, so explain how it is used and keep any sharing within the privacy rules covered under Design Responsibly.
Engagement can also come from budgeting tools, savings features and design rather than rich points; once built, these add no reward cost per customer and fit the goal of improving customers' financial position.
Fit Each Line of Business
Financial services covers businesses with different products, rules and customer relationships, so the program design changes with each.
|
Line of business |
What to reward |
What to avoid |
|---|---|---|
|
Banks and credit unions |
Direct deposit, multiple suitable products, digital banking, savings habits |
Bonuses advertised without required terms; calling an account "free" when fees can apply |
|
Card issuers |
Spend in chosen categories, on-time payment, engagement with benefits |
Devaluing earned rewards; rewards that encourage carrying a balance |
|
Insurers |
Risk reduction, safety, wellness and education services related to the coverage |
Rewards that work as an unlawful rebate or inducement to buy or renew |
|
Wealth and brokerage |
Planning, goal setting, education, consolidating accounts |
Rewards tied to trading frequency or to particular products |
|
Fintechs |
Healthy money habits, engagement with tools, referrals |
Rewards that depend on borrowing or on fees the customer did not expect; promotions that imply deposit insurance the product does not have |
Credit unions and community banks can start simply: one or two relationship tiers based on direct deposit and product count, with rewards that fit their budgets, such as fee waivers or rate bonuses. Larger institutions with several lines of business need to decide early whether customers see one program across all of them or separate programs by product. A single program usually means sharing customer data across affiliates, and the affiliate marketing rule under the Fair Credit Reporting Act (12 CFR 1022.21) generally requires notice and a chance to opt out before an affiliate uses certain shared data to market to a customer.
Each line of business funds rewards differently. A card program pays rewards from the revenue the card earns, a deposit program from the margin on the balances it attracts, and either one loses money when the reward cost is higher than the margin earned on the extra balances, products or retention it brings. Debit rewards are harder to fund at larger banks because Regulation II caps debit interchange fees for issuers that, with their affiliates, hold $10 billion or more in assets; banks and credit unions below that size are exempt from the cap (12 CFR 235.3 and 235.5).
Design Responsibly
Financial loyalty programs operate inside consumer finance, privacy, fair-lending and insurance rules. The points below cover the rules that most often affect program design.
- Earned rewards. The CFPB's Circular 2024-07 answers "Yes" to whether credit card issuers can "violate the law if they or their rewards partners devalue earned rewards or otherwise inhibit consumers from obtaining or redeeming promised rewards," including where "the redemption values of rewards that consumers have already earned or purchased are devalued." It is guidance rather than a rule, it addresses credit cards, and CFPB guidance can be withdrawn, so confirm it is still in effect before relying on it. The underlying point rests on the statute below rather than on the circular alone, and it applies widely: give notice before changes and honor value customers have already earned.
- Unfair, deceptive or abusive practices. Federal law lets the CFPB act against "an unfair, deceptive, or abusive act or practice" in connection with a consumer financial product or service (12 U.S.C. 5531), and state attorneys general and regulators can also bring actions under the same law (12 U.S.C. 5552), so the way rewards are described, conditioned and changed matters as much as the rewards themselves, whatever federal enforcement priorities are at the time.
- Deposit bonuses. Under Regulation DD for banks and savings institutions (12 CFR 1030.8), and the parallel NCUA rule for credit unions (12 CFR 707.8), an advertisement that states a bonus must generally give, where applicable, the annual percentage yield, the time requirement, the minimum balance to obtain the bonus, any higher minimum to open the account and when the bonus will be provided, with fewer items required in broadcast and outdoor advertising and in-branch signs exempt from the bonus rules. An account cannot be called "free" or "no cost" if any maintenance or activity fee may be imposed. The rule's definition of a bonus is broad, covering a premium, gift, award or other consideration worth more than $10 in a year given for opening, maintaining, renewing or increasing an account balance (12 CFR 1030.2), so relationship rewards on deposit accounts can count as bonuses and bring account disclosure duties (12 CFR 1030.4) as well as advertising rules.
- Fair lending. Regulation B says a creditor "shall not discriminate against an applicant on a prohibited basis regarding any aspect of a credit transaction" (12 CFR 1002.4). Relationship pricing, credit-linked rewards and targeted offers need a fair-lending review, including a check of outcomes across customer groups. Regulation B generally bars creditors from asking applicants about characteristics such as race or sex outside mortgage lending (12 CFR 1002.5), so that check often relies on geography or statistical proxies, and holdout and offer groups should be assigned at random.
- Sharing data with rewards partners. Under Regulation P, which covers banks, credit unions and many other financial companies (broker-dealers follow the SEC's Regulation S-P and insurers follow state rules), an institution generally may not disclose nonpublic personal information to a nonaffiliated third party unless it has given a privacy notice, an opt-out notice and a reasonable opportunity to opt out, subject to listed exceptions (12 CFR 1016.10). State privacy laws, such as California's, can also apply to program data that federal financial privacy rules do not cover. Settle data flows with rewards partners before launch.
- Insurance. State insurance laws restrict rebates and inducements not specified in the policy. The NAIC's model Unfair Trade Practices Act allows insurers to offer value-added products or services that relate to the coverage and are designed for purposes such as loss mitigation, education or to "enhance financial wellness," at a cost reasonable in comparison to the customer's premiums and offered in a way that is not unfairly discriminatory, and allows non-cash gifts within a cost limit set by the state, as long as the customer is not required to buy or renew a policy in exchange. States adopt the model individually, so check each state's law.
- Brokerage. Broker-dealer programs also sit under SEC and FINRA rules. FINRA Rule 2210 requires that member communications be "fair and balanced," which applies to how rewards and account-transfer offers are promoted.
Taxes can also apply to rewards and bonuses, depending on how they are earned, so confirm reporting with a tax adviser before launch. The guide to loyalty in regulated industries covers compliance across other regulated categories. This is general information, not legal advice; confirm the requirements for each program with counsel.
Measure Relationship Depth
Because the goal is a deeper, healthier relationship, measure depth and outcomes, not spend alone.
|
Measure |
What it shows |
|---|---|
|
Products per customer |
Whether relationships are broadening, counting only products that suit the customer |
|
Primacy rate |
Share of customers meeting the program's definition of a primary relationship |
|
Retention |
Customers and balances kept over a year, compared with similar customers outside the program |
|
Share of balances |
Deposits and investments held with the institution, where estimates are available |
|
Well-being actions completed |
Savings transfers kept, balances paid down, goals reached |
|
Complaints and opt-outs |
Signs that rewards or changes are damaging trust |
|
Reward cost per retained relationship |
Total program cost divided by relationships retained above a comparison group |
Customers who join a relationship program are often already engaged, so compare them with a holdout or with similar customers who were not offered the program before claiming it caused their behavior; BLOYL supports A/B testing against a control group for this kind of comparison. Treat growth in borrowing or product uptake that does not serve the customer as a warning sign, not a success.
Conclusion
In financial services, a points program on its own is easy to copy; a trusted relationship is not. Recognize the whole relationship rather than single products, reward actions that improve customers' financial health, fit the design to each line of business and stay within the rules on rewards, data, fair lending and insurance. Measured against a holdout, a program built that way shows whether it is deepening relationships and keeping the trust they depend on.
Build Loyalty on Trust
Brandmovers builds financial services loyalty programs on BLOYL, with relationship tiers, a rules engine for earning by segment and behavior, and testing against a control group.
Sources
- Gallup, "Risks to Banks From Rise of Digital Banking" (October 30, 2015)
- Gallup, "Customers Want Banks to Improve Their Financial Well-Being" (May 27, 2015)
- Consumer Financial Protection Bureau, "Issue Spotlight: Credit Card Rewards" (May 9, 2024)
- Consumer Financial Protection Bureau, Circular 2024-07: Design, marketing, and administration of credit card rewards programs
- 12 U.S.C. 5531, Prohibiting unfair, deceptive, or abusive acts or practices
- 12 U.S.C. 5552, Preservation of enforcement powers of States
- 12 CFR 1030.8, Regulation DD advertising rules
- 12 CFR 1030.2 and 1030.4, Regulation DD definitions and account disclosures
- 12 CFR 707.8, NCUA Truth in Savings advertising rules
- 12 CFR 235.3 and 235.5, Regulation II debit interchange standards and exemptions
- FINRA Rule 2210, Communications with the Public
- 12 CFR 1002.4, Regulation B general rules
- 12 CFR 1002.5, Regulation B rules concerning requests for information
- 12 CFR 1022.21, FCRA affiliate marketing opt-out
- 12 CFR 328 Subpart B, FDIC rule on misrepresenting insured status
- 12 CFR 1016.10, Regulation P limits on disclosure to nonaffiliated third parties
- NAIC, Unfair Trade Practices Act (Model 880), 2020 revisions


