Skip to content
BOL Conferences
Thread Options
#2147905 - 09/28/17 02:10 PM DDA Bonus
Compliance Risk Offline
Member
Joined: Sep 2015
Posts: 81
Can we require customers to make a deposit to their interest bearing checking account before we pay the bonus and still be in compliance?

Return to Top
Deposits and Payments
#2147918 - 09/28/17 03:17 PM Re: DDA Bonus Compliance Risk
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
You can put whatever restrictions you want on giving them the bonus as long as it is properly disclosed. Who opens accounts without an initial deposit though?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2147958 - 09/28/17 05:34 PM Re: DDA Bonus Compliance Risk
Compliance Risk Offline
Member
Joined: Sep 2015
Posts: 81
When Reg Q was effective, we needed to have no minimum balance and no minimum duration to obtain the bonus. Reg DD has the bonus disclosure requirements, but there are no other requirements for the bonus?

Return to Top

Moderator:  John Burnett