I'm trying to understand how ABC Bank (a hypothetical national bank) can give new mortgage customers $100, deposited into either a new or existing deposit account with ABC Bank without the $100 being seen as interest paid (per Reg. Q) on the deposit account (assuming deposit account is a demand deposit). I see the $100 as an incentive for the customer to open or use a checking account with ABC Bank.

*I understand that there's a proposal to repeal Reg. Q.*

How is the above scenario different from my earlier post regarding the giving of a gift card for a mortgage referral to which Randy replied that it is not permitred under RESPA?

The difference would be that the benefit is going directly to the mortgage customer. There is no referral.

It's not an incentive tied to the deposit account - it is solely based on getting a mortgage loan so it would not fall under Regulation Q which will be repealed anyway on 7/21.

Agreed Randy!