I need some help, please... We have a loan officer that does marketing for our bank and never runs any of the advertisements through the compliance department. The loan officer is advertising in the local newspaper a $50 gift card for a new auto loan.

I can't think of a regulation that he has violated by giving a $50 gift card for the auto loan. I know that reg DD would come in to play if it had involved a new checking account.

Is my thinking correct or am I totally off?? Please help.

I do not know of a loan reg violation either. Personally, I would watch for fair lending, just be sure no protected class is left out of the promo.

I hope someone who knows for sure will chime in, but I think with the elimination of Reg Q you wouldn't have to worry about deposit now either.

The OSC on Section 226.18(b), #2, gives you the option to ignore the gift card when preparing TIL disclosures. (I don't know the answer, but) do you have to report it to the IRS as taxable income to the borrower?

I believe you do an IRS form 1099 if it is $600 or more in any calendar year.