With rates dropping, my marketing dept wants to create a promo whereby if a customer refi's his mortgage with us, we will open a non-interest bearing account that requires direct deposit, and give him $200 into this account for refinancing his loan. Marketing wants to drum up new deposit accounts AND loans.

I took Andy and John's course on Bonuses and this exception was noted:

b) Notwithstanding paragraph (a) of this section, any premium that is not, directly or indirectly, related to or dependent on the balance in a demand deposit account and the duration of the account balance shall not be considered the payment of interest on a demand deposit account and shall not be subject to the limitations in paragraph (a) of this section.

No minimum balance requirement for the account or duration requirement, just direct deposit. But I am concerned that the only way to get this account, if the above exception holds true, is to refi the mortgage, and whether there are any RESPA concerns with this.

Don't you just love Marketing?!?

BUMP

If the benefit goes to the customer, there are no RESPA implications.