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Draw on your HELOC and receive a $75 Gift Card

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Question: 
Our marketing department would like to send out a letter with an offer to existing HELOC customers with available credit balances over $10,000 to encourage them to draw on their lines. The offer is if they draw $10,000 or more, they will receive a $75. gift card. Are there any compliance concerns? I can't think of any.
Answer: 

If the miscellaneous income given to the customer through this program and all other programs offered by the bank adds up to $600 or more in a calendar year, you would have to report it under the 1099-MISC guidelines.

First published on BankersOnline.com 8/13/07

First published on 08/13/2007

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