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Rebates-Bonus and Reporting on 1099-INT

08/23/2020

We are rolling out a new rewards program. For members who maintain multiple accounts with direct deposit and have an average balance of at least $XX,XXX, we’re going to rebate X% of each debit card purchase, up to $100 per year. I was reading some compliance discussions that noted if the credit/rebate is tied to a service instead of just opening and maintaining an account, then it would not be considered a bonus or need to be reported on a 1099-INT. In this case, the accountholder would first need to qualify for a certain level on our rewards program based on their products and balance. However, to receive the rebate, they would need to use their debit card to receive the rebate reward up to $50. We are leaning towards the rebates not being a bonus or reported on a 1099-INT as payment is triggered on the use of their debit card, not solely on opening or maintaining an account. Thoughts?

Moving Matured IRA/CD to MMA

01/05/2020

I have a client with a matured IRA/CD. Will there be a penalty if they move the matured IRA/CD to a Money Market Account? The client is 72 years old. They want to use the money for a down payment for property.

IRS Levy for Individual-No Personal Account

11/04/2018

We received an IRS levy for an individual. We have no personal account, but there is an account where the individual is the sole owner on a business account and incorporated. Does the levy effect this account? And do the new Beneficial Ownership regulations impact this at all? This individual is really using this as a personal account and even deposits Social Security checks into it.

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Credit bureau checks for new accounts

11/17/2024

What types of accounts does a financial institution need prior authorization for from a client before running Chexsystems? How does a financial institution have to notify a client that they are going to run Chexsystems? Regarding business clients - we run biz Chexsystems on the business and the beneficial owner, correct? How do we have to notify them that we are pulling their credit to determine if we can open a new account?

Banking a sole proprietorship insurance agency

11/17/2024

When banking an insurance agency that handles only cash deposits, what documents are required? Do we have to obtain their contract agreement, if they are a sole proprietorship and are licensed with multiple agencies? I am located in Georgia and regulated by the OCC.

Powers of an authorized signer on a trust account

11/10/2024

A trustee has appointed an authorized signer (not a successor trustee in this case) to their trust. The trust documents give them the power to do this. If the trustee who appoints the authorized signer dies, when do the powers of the authorized signer cease? At the time the trustee's death, or when new trust documents are drafted by the successor trustee(s)?

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