[tcranshaw]

We offer a $150 bonus if you open any new checking account. $75 for establishing a minimum monthly direct deposit of at least $200.00 and $75 for a signature based transaction of $50.00 or more. Every checking account requires a minimum opening balance of $25.00. We understand that Reg. DD ties a bonus to the “opening, maintaining, renewing or increasing” an account balance. So here are our questions:

1. The bonus is tied to direct deposit and debit card transaction so it wouldn’t be considered a bonus under Reg. D. However, does the fact that the checking account requires a minimum opening balance change this?
2. Could the requirement to establish a minimum monthly direct deposit of $200.00 be considered “maintaining” under Reg. DD and require a TISA?

[rcooper]

Find the answer to the second part of your question here: https://mycomplianceresource.com/forums/topic/account-bonuses/.

As for the first part of the question, the minimum balance required to open the account should not affect whether the direct deposit and signature based transaction requirements are considered a bonus.

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