Question: If the Bank offers an interest-bearing checking account with perks such as: 1) sign up for direct deposit and the Bank will add $50 to your account after your first direct deposit, or 2) pay a bill online and the Bank will add $50 to your account after your first bill payment transaction - are these perks considered bonuses that need to be disclosed under Reg DD?
Answer: A bonus under Reg DD is defined at 12 CFR 230.2: (f) Bonus means a premium, gift, award, or other consideration worth more than $10 (whether in the form of cash, credit, merchandise, or any equivalent) given or offered to a consumer during a year in exchange for opening, maintaining, renewing, or increasing an account balance. Since your "perks" are not being offered in exchange for opening, maintaining, renewing, or increasing an account balance, but instead for using an ancillary product (direct deposit & bill pay) they would not be considered bonuses.
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