05/12/2019
We are offering members a $100 incentive bonus if they open a checking account with direct deposit which would start within 60 days. We understand all of the disclosure requirements for the $100 payment. The argument is, must we disclose in the ad that the $100 will be reported as interest to the IRS? We of course will be sending the member a 1099-INT and reporting it to the IRS, but are we required to disclose that?
07/23/2017
Why can't we hold customers liable for carrying their PIN with their card?
08/30/2010
Are there any restrictions about how an institution pays cash bonuses? For example, can you offer a $50 cash bonus to be deposited into a savings account after the customer opens a demand deposit account?
07/05/2010
How can I enhance the deposit volume of my bank?
07/13/2009
My bank would like to extend a bonus to a new consumer checking account customer at the end of 90 days, provided the account is in good standing. From a radio spot advertising perspective, could someone explain to me the differences between (d)(2) and (d)(5) when it comes to exemption provided in section (3)? I find nothing in the regulation itself or the OSC that provides me with any guidance.Section 230.8 (d) Bonuses. Except as provided in paragraph (e) of this section, if a bonus is stated in an advertisement, the advertisement shall state the following information, to the extent applicable, clearly and conspicuously: 1) The “annual percentage yield,'' using that term;2) The time requirement to obtain the bonus; 3) The minimum balance required to obtain the bonus; 4) The minimum balance required to open the account, if it is greater than the minimum balance necessary to obtain the bonus; and 5) When the bonus will be provided. (e) Exemption for certain advertisements--(1) Certain media. If an advertisement is made through one of the following media, it need not contain the information in paragraphs (c)(1), (c)(2), (c)(4), (c)(5), (c)(6)(ii), (d)(4), and (d)(5) of this section: (i) Broadcast or electronic media, such as television or radio;(ii) Outdoor media, such as billboards; or(iii) Telephone response machines.
05/11/2009
We offer a bonus for certain accounts of $100 or more. In our advertisements we state that the account must remain open for X months. We offer payment of the bonus long before this, as incentive for consumers to open their accounts. Is there any problem with us capturing this bonus if they close before the X date? Our Reg DD disclosures state that there is a $25 early closure fee when an account is closed within the first 90 days. The bonuses above extend well beyond this 90 days. Is that a problem as our ads stated X months?
04/20/2009
When giving a gift card for opening a checking account, other than the requirements of what needs to be in the advertisement, do we have to disclose this on the TISA disclosures too?
07/07/2008
If the bank offers free tickets to a theatre (value of tickets are over $10) for opening a new checking account, but the bank received the tickets for free from the theatre company, is it still a bonus? If the bank uses these same tickets in a drawing at their grand opening, are there any concerns?
05/26/2008
If the bank offers free tickets to a theatre (value of tickets are over $10) for opening a new checking account, but the bank received the tickets for free from the theatre company, is it still a bonus? If the bank uses these same tickets in a drawing at their grand opening, are there any concerns?
05/19/2008
Our bank would like to conduct a promotion on our non-interest bearing checking accounts by giving cash bonus ($25) for opening a new account with a $100 opening deposit requirement. We do not require customer to keep the account open or the opening deposit for any period of time. Are we compliant with Reg. Q or in violation of paying interest on DDA?