Skip to content
BOL Conferences
Thread Options
#689637 - 02/20/07 06:26 PM Premiums on demand deposits- Reg Q
Anonymous
Unregistered

How can someone offer something like this: BOA offer on non-interest bearing checking accounts? Certainly it shouldn't be reported as interest!

Return to Top
Deposits and Payments
#689748 - 02/20/07 07:25 PM Re: Premiums on demand deposits- Reg Q
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Isn't this a Privacy issue? This is in the 2nd paragraph, 4th sentence:
Quote:
All referring customers will receive their incentive via check after we verify that the new customer opened a qualifying new checking account.


If I recommend John and he opens a qualifying account, I get $25. When I get the $25, isn't' the bank telling me that John has an account there?

Sure smells like a Privacy issue to me.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top
#689796 - 02/20/07 07:54 PM Re: Premiums on demand deposits- Reg Q David Dickinson
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Unless, as part of the new account opening process, there is a one-time release given by the new customer.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#689822 - 02/20/07 08:10 PM Re: Premiums on demand deposits- Reg Q John Burnett
Anonymous
Unregistered

Is there something I missed in Reg Q, or are they just swallowing the risk of noncompliance? (unless they reclassed these accounts specially for Reg D)

Return to Top
#689833 - 02/20/07 08:13 PM Re: Premiums on demand deposits- Reg Q
MN Banker Offline
Platinum Poster
Joined: Aug 2006
Posts: 980
If they are not requiring a specific balance in the account or a duration of an account balance, then it wouldn't be considered interest.

Return to Top
#689873 - 02/20/07 08:39 PM Re: Premiums on demand deposits- Reg Q MN Banker
Anonymous
Unregistered

Yes- directly or indirectly related. That's why this doesn't make sense:

1 You will receive your $50 credit to your new account within 50 days of opening your new personal checking account online. Limit one $50 incentive per household every 6 months. Offer valid only for new MyAccess Checking® accounts. You must use the Offer Code CH50MA and fund your account with the $25 minimum opening deposit requirement in order to qualify for this offer. We may report the value of any premium to the IRS. Offer expires on 12/31/2007. Offer may be withdrawn or modified at any time without notice. The $50.00 credit can only be made to your new account. This new account must be still open at this time to receive your $50.00 credit.

MyAccess® checking is free with a monthly direct deposit. Otherwise, the monthly maintenance fee is $5.95 a month. Online Banking requires Internet access. Charges for other account-related services still apply.

Return to Top

Moderator:  John Burnett