My concern is 217.101 Premiums on deposits:
"Premiums, whether in the form of merchandise, credit, or cash, given by a member bank to a depositor will be regarded as an advertising or promotional expense rather than a payment of interest if:
(1)The premium is given to a depositor only at the time of the opening of a new account or an addition to an existing account;
(2) No more than two premiums per account are given within a 12-month period; and
(3) The value of the premium or, in the case, of articles of merchandise, the total cost (including taxes, shipping, warehousing, packaging, and handling costs) does not exceed $10 for deposits of less than $5000...
The way our check printing fee is assessed is a debit to the customer's account by the check printing company. If instead the bank pays the check company directly for the checks for the customer, can it still be considered absorption of expenses or forbearance from charging a fee?