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#712793 - 04/06/07 05:27 PM Reg Q business checking bonus
terpsfan Offline
Diamond Poster
Joined: Feb 2007
Posts: 2,059
when reading the exception to reg Q I can tell if it is saying that it can be either tied to the balance or duration or if both.
Because we were going to offer a bonus to a business checking account based on a certain opening balance but how long they keep it will not matter

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#713139 - 04/06/07 10:25 PM Re: Reg Q business checking bonus terpsfan
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
Both. The exception in §217.101(b) states:

(b) Notwithstanding paragraph (a) of this section, any premium that is not, directly or indirectly, related to or
dependent on the balance in a demand deposit account and the duration of the account balance shall not be
considered the payment of interest on a demand deposit account and shall not be subject to the limitations in
paragraph (a) of this section.


If you don't have both a minimum balance OR a duration requirement, you don't have to limit the "bonus" as required in §217.101(a) - (to $10).
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David Dickinson
http://www.bankerscompliance.com

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#713298 - 04/09/07 01:38 PM Re: Reg Q business checking bonus David Dickinson
terpsfan Offline
Diamond Poster
Joined: Feb 2007
Posts: 2,059
What about giving a bonus for a service such as if a bonus sets up a business checking account and sign up for 6 months of bill pay they get a bonus

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#713383 - 04/09/07 03:54 PM Re: Reg Q business checking bonus terpsfan
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Tying the bonus to a product or service in addition to the checking account is a favorite way of getting around the rule, because the bonus is paid for the auxiliary service (bill payment, direct deposit, debit card, etc.), not for the DDA account.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#713454 - 04/09/07 05:18 PM Re: Reg Q business checking bonus John Burnett
terpsfan Offline
Diamond Poster
Joined: Feb 2007
Posts: 2,059
thank you the only thing I was worried about was requiring them to sign up for bill pay for 6 months which of course they would need to have a checking account to continue with bill pay for 6 months

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