Currently we have a customer referral program whereby we give an existing customer a free gift if they refer a person to our bank and they open an account.

In order for us to increase referrals, we wanted to target our business clients whereby they would give their employees or other community members a referral coupon. The person opening the new checking account will receive a free gift. The organization that referred the person to the bank will receive $10.00 per referral. We do have some nonprofit community organizations that we are looking at targeting. Would the $10 per referral be considered a promotional gift or a donation to the organization?

Please remember that you cannot do this for residential mortgage loans and home equity lines of credit.

Also consider privacy issues. If the $10 is given only on condition of the individual actually opening an account, then you are giving confirmation that the individual now has an account with you.

sorry, thought I was logged in. I found my answer in 3500.14