We will be offering three separate reward accounts later this year. I have two questions.
1) One of the accounts is non-interest bearing checking account that rewards the consumer with cash back if they meet the qualifications (i.e. X number of POS purchases that post and settle, X number of ACH credits that post and settle, etc.).
My question is this, is the cash back considered a bonus under TISA? I need clarification on the second part of the bonus requirement "...given or offered to a consumer during a year in exchange for opening, maintaining, renewing or increasing an account balance." My challenge is whether the events qualifying for the reward (X number of POS and ACH credits) meet this definition. I know the reward would/could exceed $10 in a year.
2) Looking back at the FDIC's CHIRO 05-2007 it appears that the bank cannot put a minimum dollar amount for transactions to qualify (i.e. consumer must have X number of POS purchases post and settle within the month - I'm paraphrasing - that are greater than $X.XX).
Has this changed? Sample disclosures I'm looking at from the vendor has the minimum purchase amount language in the samples but CHIRO 05/2007 says you can't do this. I can't seem to find anything out in cyber-land that speaks to this prohibition going away.
Any help would be appreciated. Thanks.