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Debit Card or Online Bill Pay & the Bonus Rule

We are thinking about offering a premium with the retail value of $49 when you open a new personal checking account and sign up for a debit card or online bill payment. The premium gift would only be paid upon first use of the debit card or online bill pay. Because the premium is being paid for activity on a debit card or online bill pay account and not for the opening of the checking account itself, does the $10/$20 demand deposit bonus rule still apply?

Answer by Randy Carey:No - the premium is not related to the deposit account, but to an ancillary service/product.


Answer by John Burnett:The second exception to the "thou shalt not pay interest on demand deposits" rule, found in Section 217.101(b) of Regulation Q and Section 329.103(e) of the FDIC's rules, provides your "out" for this type of incentive.

First published on 10/02/06

First published on 10/02/2006

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