Answer:
Regulation Q doesn’t apply because you’re not paying the new customer for his or her deposit or loan. The regulation has nothing to do with loans, anyhow. As you have said, you are paying the referring party. You should review how you plan to refrain from divulging non-public customer information when paying the incentives (Privacy requirements), and conform to the IRS rules on reporting non-employee compensation (on form 1099-MISC).
First published on BankersOnline.com 8/17/09