Skip to content
BOL Conferences
Thread Options
#646056 - 12/01/06 10:31 PM Customer Referral Program and Reg O
jjames Offline
Member
Joined: May 2005
Posts: 51
We are in the process of implementing a customer referral program where each referrer would receive a $25 gift card for each referral. If a director, principal shareholder, or insider refers a customer, will Reg O permit us to also give them a gift card? Thanks!

Return to Top
Marketing
#646133 - 12/02/06 03:24 PM Re: Customer Referral Program and Reg O jjames
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Sure - this has nothing to do with preferential treatment. However, if these referrals related to RESPA related transactions, the exemption to Sec. 8 is only related to bonified employees. A director or shareholder may not actually be an employee of the bank.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z, MoneyMaker