Fee for Referring Non-Customer/Invest CD

Yes, this would be called a bonus and there are several issues that need to be considered. When advertising the offer, be sure to follow the requirements for bonuses in Reg DD at section 1030.8(d), and when the account is opened follow the new account disclosure requirements in 1030.4(b)(7). Also, consider privacy considerations. Remember that "personally identifiable financial information" includes "the fact that an individual is or has been one of your customers or has obtained a financial product or service from you." [1016.3(q)(2)] IRS interest reporting requirements also come into play if $10 or more of interest is paid. The IRS considers a bonus for opening, adding to, or maintaining an account to be interest.