1. Implement this product as specified, doing everything in my power to ensure rules are being followed throughout.
2. Quit my job in protest, bringing down my tiny startup company. 10 people are immediately out of work. Our client finds someone else to implement chex for them anyways.
I think we are coding ourselves into dystopia - where technology will not be serving us, but we will be serving it. We might be there already.
Which 'governance structure'/'rule creating structure' is going to ensure that the moral elements are considered? Or do they simple wave through the legislation big corporations' lobbyists have written? Will big corporations' so-called the 'ethics committees' give us the moral outlook we need? (I don't think so - they are about justifying the unjustifiable, it seems to me.) What is better - that 10 people you are out of work, or that - as you say - someone else will implement this?
These questions are very hard to answer. There are lots of coders who will do whatever-it-is without hesitation.
Ultimately, I guess we will have to do as we each see fit. What I say: morality is a question for the individual, so how do you judge yourself? That is one way to guide oneself through the mire.
In my experience, many are simply doing it as a form of KYC (i.e. customer authentication) than an actual "is this a bad customer" check.
I have seen some really janky shit too. Every FI I have ever worked with ultimately decided to implement some "exception" process to be able to work with customers when there is some system outage or other unexpected results come back.
Additionally, every institution I worked with also provides some form of second-chance product offerings to customers who come back with a red-hot report. Obviously, these products do not offer overdraft or other line-of-credit features, but they are real checking accounts for all other purposes.
From my perspective, it's not an ideal system. But then again, I don't know that ideal is possible or desired. I think if Chex didn't exist, something else certainly would take its place. I've watched some other vendors exit the space recently, so I think they are now the last/biggest player.