The Marketing department wants to send out a letter to our customers 50 and over that says basically that since you are our customer, here is another checking account and that if you open an account and then enroll in any of these additonal services, we will deposit $5 into your account-up to $25. The services are e-statements, direct deposit, internet banking, and mobile banking, etc. These are all free services and the $5 would act as an incentive to get them into these electronic services. It is only offered for a certain period of time. The $5 will be deposited into the account within the next few days. Thank you!

You've made marketing's plan pretty clear. What is it that you are asking about?

Wanted to make sure we were not running into anything that could be a problem with paying $5 for signing up for these services.

No problem I can see.

I agree with John.

Only item I might be concerned about is if Marketing wanted to include or incent for overdrafts, or any other sort of lending. That is where the magic number is 62 rather than 50.

As long as you clearly disclose the program and any limitations you should be fine.

I'm with Southern Banker. If you pay an incentive based on age for a service relating to the extension of credit, you're offering preferential terms. If the age criterion is something "more youthful" than age 62, you'd be open to criticism for Reg B violations.