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#1173186 - 04/30/09 02:56 PM Recovering the cost of a bonus offering
Banker83 Offline
Junior Member
Joined: Sep 2007
Posts: 34
We are offering a "bonus", approx. $200, to consumers who open an interest bearing account requiring them to keep the account open for a certain period of time and opened for a certain amount. If that customer closes the account before the required time period we would like to recover the cost of the bonus whenever possible and would disclose the closing fee in our marketing materials. Are there any regulatory restrictions on the amount you can charge as a closing fee?

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#1173249 - 04/30/09 03:23 PM Re: Recovering the cost of a bonus offering Banker83
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Not that I'm aware of.
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David Dickinson
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#1173805 - 04/30/09 09:05 PM Re: Recovering the cost of a bonus offering David Dickinson
ckb Offline
Member
Joined: Apr 2009
Posts: 80
To piggyback on the original question...if our Fee Schedule states that there is a $25 early closure fee (closed within 90 days of opening), can we recover the full bonus amount (exceeding $25) if this is disclosed in the original marketing materials? Or would the Fee Schedule supercede the marketing materials?

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#1173912 - 05/01/09 02:58 AM Re: Recovering the cost of a bonus offering ckb
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
It would have to be in the Truth-in-Savings disclosure. Marketing materials do not count as a disclosure. Good luck in ever collecting if the customers run their accounts to zero.
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#1179311 - 05/08/09 04:57 PM Re: Recovering the cost of a bonus offering rlcarey
Banker83 Offline
Junior Member
Joined: Sep 2007
Posts: 34
To add to that if you want to prepare a simple ad for a bonus, how simple can it be and still attract attention, i.e. picture of the bonus with a brief "get this when you open a checking account?"

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