One of the most problematic features of many such programs is that some of their "benefits" have to be claimed by the customer. For example, if a program offers fee-free cashier's checks to customers who maintain a qualifying relationship balance, it's OK if the bank rep selling the cashier's check can always determine whether a customer is qualified and automatically waives the fee for qualified customers. It's not OK if the customer has to remind the rep that he or she is entitled to the benefit.
I do encourage you to read through the thread that Reads Regs linked to. It mentions several of the pitfalls of rewards programs.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8