We are rolling out a new rewards program. For members who maintain multiple accounts with direct deposit and have an average balance of at least $XX,XXX, we’re going to rebate X% of each debit card purchase, up to $100 per year.
I was reading some compliance discussions that noted if the credit/rebate is tied to a service instead of just opening and maintaining an account, then it would not be considered a bonus or need to be reported on a 1099-INT. In this case, the accountholder would first need to qualify for a certain level on our rewards program based on their products and balance. However, to receive the rebate, they would need to use their debit card to receive the rebate reward up to $50.
We are leaning towards the rebates not being a bonus or reported on a 1099-INT as payment is triggered on the use of their debit card, not solely on opening or maintaining an account. Thoughts?
During a recent compliance forum I understood the consultant to say that the 7 day notice of withdrawal language needed to be a part of the TISA disclosure – even if it is part of the terms and conditions disclosure. It is not at our bank.
I spoke with a bank manager that has a background in compliance but has been out of the deposit compliance loop for several years. He says that as long as it was in our T&C then we should be fine.
I can’t get what the consultant said out of my head – can you help? Is there a citation that addresses this in Reg DD or Reg D? Maybe I misunderstood?
Is the bank required to disclose that a bonus paid will be considered interest and be reported on a 1099-Misc? Should the information be
disclosed in the advertisement of a bonus?
We are advertising a $125 bonus that will be paid when a customer completes a few requirements, including opening 1 of 3 various non-interest and
interest-bearing checking accounts, signing up for a direct deposit, and using our mobile banking app. I wasn't planning to disclose an interest
rate or APY to avoid the additional disclosures caused by the trigger term. However, when disclosing a bonus, the APY appears to be a requirement. I wanted to verify that we have to disclose the APY (using the term annual percentage yield) and the additional disclosures caused by this trigger term
if we are disclosing a bonus. Or, does the APY disclosure requirement for a bonus not apply if we were not planning to disclose the interest rate or
APY? Also, are we required to use the word "bonus" in our ad?
We are currently in the process of changing our fees. Some fees may increase and some fees may decrease. With that said do we still need to
send a notice to customers 45 days in advance of the changes?
We are offering members a $100 incentive bonus if they open a checking account with direct deposit which would start within 60 days. We understand all of the disclosure requirements for the $100 payment. The argument is, must we disclose in the ad that the $100 will be reported as interest to the IRS? We of course will be sending the member a 1099-INT and reporting it to the IRS, but are we required to disclose that?
We are making changes to a checking account that we offer, we are going to implement a monthly fee. Because this will negatively impact our members, don't we have to notify them and how much time do we need to provide before making the change?
We have an upcoming deposit account fee change requiring advance notice to affected account holders. If we know we have a bad address (statements have been returned), are we required to mail the notice to the last known address?
Is a bank required to give its business customers a schedule of fees?
Are dormant accounts not subject to receive a monthly statement, or is it still required to be sent via Reg DD?