We are changing a particular checking product and will start charging a fee for not having estatements. We would like to offer a $5 gift card as an incentive for accountholders to sign up for estatements on this account before the change becomes effective.

Is it permissible to offer the incentive on our website, in the lobby, and at new accounts desk for this one product only? Must you send the offer to all owners of that type of product? Must you extend the offer to all customers not matter what type of checking account they have?

I know this is a weird question, but can someone help??? I need an answer quickly.

Your difficulty in finding respondents may be in that you are looking for laws or regulations to direct your actions when none exist for most of them. Just some observations:

* "Charging a fee for not having e statements" might be a bit easier to understand if you changed it to charging a fee for receiving a paper statement. That has become commonplace; i.e. if customers want a paper statement, they pay for it. If this is a new fee not mentioned in the customer's TISA disclosure at account inception then you would give 30 days advance notice to all affected account holders.

* You may offer incentives on some account types but not others as you see fit.

* You may discriminate and not send all owners of the account type notice of the incentive, but it's difficult to imagine why...