Our mortgage department is looking to run a promotion in which we'll say, "We'll pay $400 of your first mortgage payment if you close your mortgage with us."

So after the loan closes, we will send the customer a check for $400. Ultimately the customer can do whatever they want with the check, we're simply marketing it such that we're paying for a portion of their first mortgage payment.

From a compliance standpoint, we're ok with that concept as described above. The issue is that now they want to also say, "...and if you also open up a checking account, we'll throw in an additional $100" (so we'd mail a $500 check instead of a $400 check). The plan is to advertise this by word of mouth throughout our branch network. There will be no flyers or newspaper ads. How would one go about Reg DD bonus disclosures in this circumstance? There's no additional requirements other than opening the account to get the additional $100 bonus. And there is no particular account that this is restricted to.

Any help is much appreciated. Thanks.

I would strongly suggest you be careful with noting the proper disclosures.

$100 bucks for opening the account, the usual 1099. If you offer the $100 for automatic payment from a checking account, that's not Reg DD