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#635668 - 11/08/06 04:25 PM Reg DD Bonuses
Last Mango Offline
Gold Star
Joined: Mar 2001
Posts: 293
Too Far From the Beach
I've received 0 repsonses in Marketing so I'll try here.

Under Reg DD, bonuses do not include waiver of fees or absorption of expenses for "banking-related services".

What is the definition of "banking related services"? In today's banking, would this include:

free insurance services such as lost key protection, auto or other insurance services?
discounts on seminars or tours for a club account?
free credit reports?
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#635669 - 11/08/06 08:14 PM Re: Reg DD Bonuses
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,034
Galveston, TX
IMHO - offering any of these as part of a deposit account package would not be considered a "bonus" under Reg DD.

Curious - how do you offer "free credit reports"?
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#635670 - 11/09/06 10:48 PM Re: Reg DD Bonuses
Last Mango Offline
Gold Star
Joined: Mar 2001
Posts: 293
Too Far From the Beach
For a particular deposit club plan, we offer several incentives, one of which is providing the customer with a free credit report. My understanding is that on request,our loan department will run the report for the customer.

I'm really struggling with understanding the regs on this one. May I ask why you do not believe that an incentive such as a discounted historic tour would not be a bonus? It would seem to me that this is not a banking related service and if the cost is more than the limit under Reg DD, then it would be considered a bonus. Am I misunderstanding this rule?
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#635671 - 11/09/06 10:56 PM Re: Reg DD Bonuses
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,034
Galveston, TX
For example, offering a slip of paper that is good for a discount on a trip or to a local restaurant has no value - it is just a slip of paper with no cash value.

You may want to check your contract with your credit bureau, because most standard CB contracts will not allow you to pull credit reports for reasons outside standard business reasons.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#635672 - 11/10/06 03:08 PM Re: Reg DD Bonuses
Last Mango Offline
Gold Star
Joined: Mar 2001
Posts: 293
Too Far From the Beach
Ahhh! I guess I was thinking like an accountant again . . . everything has value. Thanks!!!
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