[rcooper]

I’m assuming the gift card the other bank is giving away is less than $10 which doesn’t qualify as a bonus and therefore doesn’t trigger the bonus disclosures. Same goes for the free box of check which would be an absorption of an expense.

From Reg DD 1030.2(f) Bonus means a premium, gift, award, or other consideration worth more than $10 (whether in the form of cash, credit, merchandise, or any equivalent) given or offered to a consumer during a year in exchange for opening, maintaining, renewing, or increasing an account balance. The term does not include interest, other consideration worth $10 or less given during a year, the waiver or reduction of a fee, or the absorption of expenses.

Jack’s Compliance Resource offers many products including policy and procedure updates, Director/Senior Manager Updates, Training Manuals, Flowcharts, Checklists and more. To access Jack’s Compliance Resource products visit our marketplace by clicking here:
Jack’s Compliance Resource Marketplace

[Author]

Posts