Not according to one vendor who has sold a product to over 600 community banks and credit unions across these United States, and their legal counsel......in one sense, to me anyway, it's no different than a tiered account (where to get a certain rate you must have xx dollars on deposit)
Our compliance consultants reviewed the marketing materials thoroughly before signing off....
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My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.