It was huge news back in 2007 when Wal-Mart dropped its controversial plans to start up an industrial bank in Utah. The retail giant was bitterly criticized by many, which made it impossible to move forward. But now, in the wake of retail anger directed at big consumer banks, Wal-Mart is back in the discussion.

Wal-Mart has not announced any plans to again seek an industrial bank charter in the United States, but it has obtained similar charters in Mexico and Canada. If--and it is a big if--the company were to reapply for a charter here, now might a good time to go for it. There is a lot of anger directed at what many perceived as onerous and sneaky fees imposed by banks in the wake of the Durbin Amendment. Bank of America's debit card fee fiasco is perhaps the best example.

At the retail level, Wal-Mart has emerged as a low-cost provider of basic financial services, like check cashing, money transfers, bill payment and the like. When all is said and done, its fee structure is seen by consumers as a decent value compared to the bigger banks. According to the New York Times, Wal-Mart research has found that more than 60 percent of the customers using its financial services had bank accounts.

"When Wal-Mart asked those people how much their banking activities cost them over the last six months, the answer was between $200 and $400."

That's the opportunity. One question here is whether the big banks will mind giving up small accounts to a new player such as Wal-Mart. Bank of America CEO Brian Moynihan has noted recently that small accounts do not contribute to the bottom line, leaving the bank to focus elsewhere.

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