Our institution has a children's savings program where they receive an annual b-day gift from opening through age 18. There are a couple years where the gifts may be over $10. Should disclosures be included on all advertising since one or two years the gifts may exceed the $10 limit?

Disclosures for what? That this is interest that they will have to claim it on their taxes? They have to claim it whether you issue a 1099INT or not. Whatever the ammount would just be added to the other interest earned that year.

I guess you can say I'm confused!! Is this a "bonus" or "interest"? This is a b-day gift given annually as long as the account is opened (maintained). Under TISA wouldn't this be considered a "bonus"? Most of the gifts are under $10 (which would not require additional disclosure under TISA), but because a couple of the gifts would go over the $10 limit do we have to provide TISA disclosures in our advertisements; such as APY, minimum balance, bonus type, etc? Any help would be appreciated. I just want to know if our ads for this savings program will require the additional TISA disclosures and of course want to make sure they're compliant. As for 1099 reporting - all the items would be considered INT? Thank you!!