We have a round up product, where we round up debit card purchase amounts to the next dollar, transfer the change over to a separate account, and we match a percentage of the rounded up amount and payout the match at the end of the quarter. Our match has an annual cap, which is well over $10. I'm trying to determine if our match that we pay out could be considered a bonus. Customers cannot transact on the account where the rounded up amounts and match amounts are held. I guess the question is would our match in any way be seen as given in exchange for opening, maintaining, or renewing an account, or increasing an account balance?

I'd appreciate some feedback on whether our match is or could be a bonus.

Your match is given based on debit card usage and is subject to 1099-MISC reporting if it exceeds $600. It is not a bonus as defined by Reg DD.

Thanks BrianC. Our materials say that the match is reported on a 1099, but our match caps at $300/year.