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#2116457 - 02/01/17 03:55 PM Bonus
GatorsFan Offline
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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.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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