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Bonuses on an Account

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Question: 
Our Marketing department would like to have a promotion in which certain new deposit accounts are given free movie tickets if they mention seeing the ad. I know that if it's for a demand deposit account, we'll have to stay within the dollar amounts set by 217.101. Marketing would like to see this as an on-going thing. Mail these customers free movie tickets periodically (as often as allowable) while the account is open.My question is in regard to (a)(1) of 217.101. I know we can do it at account opening, but I'm reading that for the periodic bonuses to go out that there must be a renewal or at least an addition to the account. I'm not familiar with the concept of a demand deposit account renewing. What would qualify under those categories? Also, how would this situation change if we were talking about non-demand accounts?
Answer: 

This is a holdover from the old days when Reg. Q covered more than just demand deposits. Section 217.101 was issued as an interpretation "back in the day," and codified to the regulation. The Fed hasn't seen the need to remove the out-dated language. If you're not dealing with true demand deposit accounts, Regulation Q simply doesn't apply.

First published on BankersOnline.com 10/29/07

First published on 10/29/2007

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