I think that you need to revisit these statements:
"For a non-interest bearing DDA you are fine per Reg Q you would have a bonus if the account is interest bearing per Reg DD. "
Defining a bonus under Reg DD has nothing to do with whether or not the account in interest bearing. It has to be more than $10, similar to the requirements of Reg Q.
"If they can get more than one then you have IRS reporting to do but thats all."
A 1099INT is triggered at $10 and this would require that you report this as interest on non-interest bearing accounts and add this amount to the interest paid on interest bearing accounts.
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