We are looking to offer a large number of rewards points with a debit card when opening a new checking account. The points can be cashed in for goods, i.e. gift cards, airline tickets, merchandise, etc. There is a minimum to open and an early closing fee to be assessed at this time. Would this be a violation of Reg Q's limitations on premiums for demand deposits? This is a little sticky since it's the bank providing our own points, so, I'm not sure that it fits exactly into the waiving of fees/free checks scenarios that are allowed by Reg Q. Any thoughts are appreciated!

Are the points for opening the account or for getting the debit card. If it is for opening the account, then you may have a Reg Q problem by imposing a minimum opening deposit. If it is for getting the debit card - it would not be an issue.