Does offering a $25 coupon for opening a regular checking account trigger anything?? All I can find for regulatory guidance is stuff on Bonuses referring to TISA and savings accounts. Searching "Bonus" in the subject line for the past 5 years yields two discussions.

What is the $25 coupon for?

...for "$25 for any new checking account opened." To me that looks like cash in account.

That's what I'm trying to clarify. The answer is different if you put $25 in my account than if you give me a coupon for a $25 discount at a local restaurant.

That is a bonus under TISA then, since it is given for opening the account.

1030.2(f) Bonus means a premium, gift, award, or other consideration worth more than $10 (whether in the form of cash, credit, merchandise, or any equivalent) given or offered to a consumer during a year in exchange for opening, maintaining, renewing, or increasing an account balance. The term does not include interest, other consideration worth $10 or less given during a year, the waiver or reduction of a fee, or the absorption of expenses.

$25 put into their new checking account. No savings accounts.

As Randy says. It's a bonus. Since the Repeal of Reg Q now permits bonuses for non-interest bearing accounts, the type of account being opened is irrelevant.

BrianC, are you telling me that TISA now covers accounts that are not Interest bearing?? Did TISA get revised?? You said "now permits bonuses" what does that mean? Are you saying that before Reg Q was repealed you couldn't give a bonus on a checking account??

TISA has always covered non-interest bearing accounts. Look at the definition of account in 1030.2(a) and accompanying commentary.

(a) Account means a deposit account at a depository institution that is held by or offered to a consumer. It includes time, demand, savings, and negotiable order of withdrawal accounts. For purposes of the advertising requirements in § 1030.8 of this part, the term also includes an account at a depository institution that is held by or on behalf of a deposit broker, if any interest in the account is held by or offered to a consumer.

(a) Account.

1. Covered accounts. Examples of accounts subject to the regulation are:

i. Interest-bearing and noninterest-bearing accounts.
ii. Deposit accounts opened as a condition of obtaining a credit card.
iii. Accounts denominated in a foreign currency.
iv. Individual retirement accounts (IRAs) and simplified employee pension (SEP) accounts.
v. Payable on death (POD) or “Totten trust” accounts.

Req Q prohibited the paying of interest on demand accounts. Since a bonus is defined as interest, you could not offer a bonus on a non-interest bearing account until Reg Q was repealed in 2011.

OK thanks Brian, I got it. I missed that part in class. You are patient. I appreciate it.

And don't forget your 1099-INT since it is more than $10.