We are offering a product that has a monthly maintenance fee of $xx.xx but the consumer may earn a $2.00 monthly credit if they have a recurring direct deposit. We have been advised that the $2.00 credit is really a bonus after 5 months. They are saying under 12 CFR 1030.2 it would be a bonus because the consumer is offered something for more than $10 in exchange for maintaining an account, however, I believe that it should be considered a waiver or reduction of a fee and would not be a bonus....any thoughts?

§1030.2(f): (f) Bonus means a premium, gift, award, or other consideration worth more than $10 (whether in the form of cash, credit, merchandise, or any equivalent) given or offered to a consumer during a year in exchange for opening, maintaining, renewing, or increasing an account balance. The term does not include interest, other consideration worth $10 or less given during a year, the waiver or reduction of a fee, or the absorption of expenses.

And from the Commentary:
4. Waiver or reduction of a fee or absorption of expenses. Bonuses do not include value that consumers receive through the waiver or reduction of fees (even if the fees waived exceed $10) for banking-related services such as . . .

What you describe is not a bonus, even if aggregated and exceeds $10.

Ahhhhh... Thank you David. I've been doing some bonus research and came across this older post and this saved me some time. I completely lost my head and forgot to read the definitions first.
P.S. I truly enjoyed your presentations at the ABA National Compliance School this year!