Answer:
It should not. Under Reg. DD you should not advertise an account as "free" unless it meets the qualifications of truly being free, but you can advertise the attributes of an account as being free.
In this case, it is not really an attribute of the account that is free, but rather a feature of the account based on the consumers tax qualifications. I would recommend footnoting the fact that this is tax-free, with some language that there are qualifications based on the customer and the account. The customer should refer questions to someone such as a tax professional, counsel, or call the bank for more information on this product.
First published on BankersOnline.com 5/11/09
print
share