Marketing has presented an idea for some of our employees to setup a table at a restaurant that offers gift cards to that restaurant if the individual opens an account with our bank.

Something in me is telling me there is something wrong with this but I am having difficulties finding anything solid. Guidance and thoughts please!

From a State law perspective? It would just be a bonus under TISA and reportable interest if over $10. Opening accounts at a location other than a branch might constitute a mobile branch and require a charter.

Thanks Randy - I don't know why but I was frozen in my thought process!