Skip to content
BOL Conferences
Thread Options
#741868 - 05/29/07 08:22 PM Gifts/Bonus
derup Offline
100 Club
Joined: Apr 2004
Posts: 103
WISCONSIN
We are going to be merging with another bank, and we have some duplicate account numbers. We will be closing all of the existing accounts and setting up new accounts for the customers (all dda accounts). We want to make the transition as smooth as possible, and would like to give the customers a gift (like a $25 gift certificate). Are we still limited to Reg. Q's $10/20 if we are doing it for our merger purpose...or does that even matter?

Return to Top
Deposits and Payments
#742013 - 05/29/07 10:23 PM Re: Gifts/Bonus derup
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I just answered this question in the Guru forums. Here's what I said there:

-----------------------------------------------------------------
Yes the rules still apply in those situations. However, there are a few loopholes to Reg Q. ยง217.101(b) states:

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 the "bonus" is not related to the balance in the account AND the duration of the account, you can pay any amount you want. Keep in mind IRS 1099 issues as well as Reg DD bonus issues if you promote these "bonuses".
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top

Moderator:  John Burnett