I am at debate over the bonus disclosure requirement from Reg DD 1030.8(d)(2), which states that the following must be disclosed : 2. The time requirement to obtain the bonus. One opinion is that this refers to the length of the promotion such as "offer valid from 03/01/2018 to 05/31/2018." The opposing opinion is that this refers to the length of time that the account associated with this bonus should be open for such as "account must be open for 90 days to be eligible." The latter opinion should not to be confused with item 5. when the bonus will be provided.

I pre-date Reg DD and will tell you that when implemented this meant - what is the requirement at opening, to be maintained and when the bonus would be paid. The intent is to inform the consumer what is necessary and for how long so that they can be compensated when.