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#1517622 - 03/04/11 03:28 PM Direct deposit minimum to receive incentive
CO Officer Offline
100 Club
Joined: Feb 2003
Posts: 202
USA
We have offered cash incentives to customers to have direct deposit added to their account. I get that this is not considered a bonus since it is not "related to or dependent on the balance in a demand deposit account".

Marketing is exploring a new twist...can they require that the direct deposit be at least xxx amount of dollars to qualify for the incentive? I wondering if this would cross over into "indirectly related to or dependent on the balance in a demand deposit account".

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Deposits and Payments
#1819302 - 05/31/13 07:02 PM Re: Direct deposit minimum to receive incentive CO Officer
LJones Offline
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LJones
Joined: Apr 2006
Posts: 156
Bump smile
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#1819320 - 05/31/13 07:20 PM Re: Direct deposit minimum to receive incentive CO Officer
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,438
Galveston, TX
What difference does it make now that Regulation Q has totally been repealed?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1819330 - 05/31/13 07:29 PM Re: Direct deposit minimum to receive incentive CO Officer
LJones Offline
100 Club
LJones
Joined: Apr 2006
Posts: 156
Argh . . . of course. blush Good thing its Friday
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#1819629 - 06/03/13 06:55 PM Re: Direct deposit minimum to receive incentive CO Officer
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Just be very sure that you are transparent in this change. "Bait and switch" can be a very potent UDAP argument for a disgruntled bunch of consumers. And you examiners won't like it, either.
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#1819654 - 06/03/13 07:21 PM Re: Direct deposit minimum to receive incentive CO Officer
LJones Offline
100 Club
LJones
Joined: Apr 2006
Posts: 156
Duly noted. Thanks.
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