We are opening three new branches. Our marketing department wants to give to the first 50 customers: $50 gift card, $100 savings bond, and $50 charitable donations in the customer's name. We have a minimum deposit for new accounts and they want the customer to sign up for direct deposit to obtain the awards. The award will be given to the customer after the first direct deposit is received into the bank. I think this is in violation of Reg Q.

Forget Reg Q. This is a lottery. No can do.

I do not see why you think this is a lottery. The first 50 customers absolutely receive a gift card, a savings bond, or a donation in their name. What defines a lottery is that entrants are providing consideration or some thing of value for a chance to win a thing of value that is greater than their entry "fee". They are not entering for a chance to win. They open a DDA account, if they are one of the first 50, if they keep their account open until at least the date of the first direct deposit is posted, and if they must meet the minimum opening balance requirement, they receive $50.00. But, can we exceed the $10$20 when we definately have a definitive amount of time the account must remain open? I don't see the lotter here.

I do not see why you think this is a lottery. The first 50 customers absolutely receive a gift card, a savings bond, or a donation in their name. What defines a lottery is that entrants are providing consideration or some thing of value for a chance to win a thing of value that is greater than their entry "fee". They are not entering for a chance to win. They open a DDA account, if they are one of the first 50, if they keep their account open until at least the date of the first direct deposit is posted, and if they must meet the minimum opening balance requirement, they receive $50.00. But, can we exceed the $10$20 when we definately have a definitive amount of time the account must remain open? I don't see the lottery here.

It can be construed as a lottery because the element of chance lies within what "gift" they receive when they open the account (the consideration)...there is no guarantee they get the $50 gift card....they may get a SB (that they are not allowed to redeem right away) or a donation made in their name (which I would rather have the SB 'cause eventually I would at least get something!) which really is winning nothing, especially when the guy at the desk next to him just got the gift card!

Just do a $50 gift card to the customers who committ to and follow thru on getting the direct deposit, when they get the first direct deposit, and life will be good.

So, if we say the first 50 new customers receive a $50 gift card for opening a deposit account (opening minimum balance requirement) and maintain that account open until at minimum the first direct deposit is received into the account (length of time) - that we comply and Reg. Q does not come into play (minimum and duration ) as interest on a demand deposit account? We do not have to limit the bonus to $10/$20?

If you qualify it by minimum opeing deposit and time and this is a DDA account - then Reg Q is going to come into play.