The Bluebird service offers consumers nearly all of the deposit services offered by a bank, including direct deposit, ATM access, electronic bill paying, while allowing checks to be deposited using a smart phone, or, of course at a WalMart store. All of the bluebird services are fee, except for a $2 fee if a customer uses an out-of-network ATM, or of a customer refills the Bluebird debt card using another debit card. So what's left? Credit. WalMart would need the ILC charter in order to begin lending to its customers. The company didn't respond to a request for comment on whether it wishes to file a new application to form a bank subsidiary. The FDIC declined to comment.