Gift card to switch to auto pymt of loan

We would like to provide an incentive to switch to automatic payment of pre-existing mortgages[$50 gift card]. Some of the mortgage customers have pre-existing checking accounts with us and others do not. The customers that currently do not have an deposit account would need to open an account to participate. I just want to know if I have my ducks in a row...

Existing deposit account - the debit card does not fall within the definition of bonus so Reg DD doesn't apply - we would need to follow IRS guidelines for 1099-MISC. Reg E disclosures would be provided.

New deposit account - falls under Reg. DD for bonus, follow IRS guidelines for 1099-MISC and give Reg E disclosures.

Am I missing anything? Thanks for the assistance...

Existing deposit accounts, correct.

New deposit accounts, OK, except it's not a bonus under Reg DD any more than it would be for an established account. The $50 is not being paid for opening, maintaining, renewing, or increasing an account or balance. It's being paid for use of the auto transfer service.

John - thank you.

You're entirely welcome. Definitions of terms are often the key to compliance questions. I know that I would be totally lost in the compliance world if I didn't know where to define the terms I am working with.