Would refunding a first check order, up to $25, on a new account, (NOW acct.) that has to be open for 90 days first, be a bonus or reportable interest?

Under Reg Q, I interpret this as interest, as the refund is given after 90 days, (a time/balance requirement) and it will be more than the $10/20 rule. I might call it the waiver of a fee or expense under Reg D, as there is no dollar limitation, but is this really the waiver of a banking related service, (wording from commentary)?

If I didn't have you all to bounce this off, I would say this is reportable interest. Please share your thoughts and expertise.

Thanks,

Deb

It is the waiver of a bank charge - not a bonus - not reportable interest.

It's not considered interest or a bonus under either Regulation DD or Regulation Q; I don't believe that the IRS would consider it interest, either.

Thanks guys. This is always a confusing issue for me.

Deb