If premiums are not "premiums" for Reg Q as discussed elsewhere on this web page, would it be a good idea to check that the bank has real demand deposits under Reg D? Reg D is a bit out of my realm of compliance expertise, but it is my understanding that a real demand deposit doesn't exist if the bank reserves the right to require at least seven days written notice before withdrawal or transfer. So feasibly, we could give away a pretty good Reg Q non-premium if certain requirements are met relative to opening DDAs, but if the bank doesn't have a real DDA under Reg D, then you have paid premiums under Reg Q?