New Account Sale - Referral Fee

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Question:

We are having a "new account sale" where we offer a gas card for opening a new account. What are the stipulations on paying the employees of the gas stations a flat referral fee for the day of the sale?

Answer:

I'm confused. The bank is giving "new customers" a gas card for opening an account. The bank wants to pay the employees of the gas station a referral fee? For the customers the gas station employees refer to the bank that open an account? As long as the account is not covered under RESPA and this would not classify the gas station employee as a deposit broker, there should not be a problem.

First published on BankersOnline.com 11/12/07