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#2116457 - 02/01/17 03:55 PM Bonus
GatorsFan Offline
New Poster
Joined: Feb 2017
Posts: 9
We offer a $150 checking account bonus for establishing a minimum monthly direct deposit of $200.00 and performing a $50.00 debit card transaction. Its my understanding that this is not a bonus under Reg. DD.

However, does that fact that we require a minimum opening balance ($25) on our checking accounts make this a bonus? Or does this not matter because regardless of whether or not a bonus is involved, the account must be opened with $25.00?

Would we want to include the minimum opening balance requirement in our advertisement to avoid any UDAAP issues?

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#2116462 - 02/01/17 04:06 PM Re: Bonus GatorsFan
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
If you are going to impose a minimum to open in connection with advertising the bonus, you should say so in your ad. I was reviewing some complaints concerning accounts and services in the CFPB's database and saw a number in which there was an apparent miscommunication of prerequisites for bonuses in connection with new accounts. Transparency is the watchword.

I'd consider the $150 to be a bonus under Reg DD because it requires a $200 deposit (direct deposit) on a monthly basis, along with the debit card transaction. Here again, the big deal is mentioning the bonus in an ad triggers a bunch of other info that has to be disclosed. But under Transparency Principles, you'd include that information in the ad anyhow.
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