We sell a $35 logo mug gift box, printed, packed and shipped to each person's address. This page quotes Regulation DD and NCUA's rule and does not tell you whether a gift is a bonus.
Key facts (12 CFR Parts 1030 and 707 on eCFR, up to date as of October 27, 2026, read October 29, 2026):
- The definition: a bonus is "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" (12 CFR 1030.2(f)).
- The $10 de minimis rule: "Items with a de minimis value of $10 or less are not bonuses" (Supplement I, comment 2(f)-2).
- Added up: institutions "must aggregate per account per calendar year items that may be given to consumers", for a specific promotion (comment 2(f)-3).
- If it is a bonus: account disclosures state "The amount or type of any bonus, when the bonus will be provided, and any minimum balance and time requirements to obtain the bonus" (12 CFR 1030.4(b)(7)).
- Credit unions: NCUA's 12 CFR 707.2(e) uses nearly the same words, and its interpretation adds: "Items required to be reported by the credit union under IRS rules are bonuses under this regulation."
More trades in client gifts by profession, including financial advisor client gifts; every limit in one table on client gift limits by industry.
What Is a "Bonus" Under Reg DD?
Regulation DD (Truth in Savings) defines the word, with two more definitions beside it:
"(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."
"(h) Consumer means a natural person who holds an account primarily for personal, family, or household purposes, or to whom such an account is offered. The term does not include a natural person who holds an account for another in a professional capacity."
"(a) Account means a deposit account at a depository institution that is held by or offered to a consumer."
12 CFR 1030.2 (eCFR, up to date as of October 27, 2026). Read October 29, 2026.
The definition's parts, in its own words:
| Part of the definition |
The words |
| A value |
"worth more than $10", "given or offered to a consumer during a year" |
| An exchange |
"in exchange for opening, maintaining, renewing, or increasing an account balance" |
| What it leaves out |
"interest, other consideration worth $10 or less given during a year, the waiver or reduction of a fee, or the absorption of expenses" |
This is information, not legal or tax advice. Check the current rule (or check with your compliance officer) before you send.
The $10 De Minimis Rule, and the Coffee Mug Example
The CFPB's official interpretation of 2(f) gives examples on both sides of the line:
"1. Examples. Bonuses include items of value, other than interest, offered as incentives to consumers, such as an offer to pay the final installment deposit for a holiday club account. Items that are not a bonus include discount coupons for goods or services at restaurants or stores."
"2. De minimis rule. Items with a de minimis value of $10 or less are not bonuses. Institutions may rely on the valuation standard used by the Internal Revenue Service to determine if the value of the item is de minimis. Examples of items of de minimis value are: i. Disability insurance premiums valued at an amount of $10 or less per year. ii. Coffee mugs, T-shirts or other merchandise with a market value of $10 or less."
"3. Aggregation. In determining if an item valued at $10 or less is a bonus, institutions must aggregate per account per calendar year items that may be given to consumers. In making this determination, institutions aggregate per account only the market value of items that may be given for a specific promotion."
12 CFR Part 1030, Supplement I (Official Interpretations), comment 2(f). Read October 29, 2026.
The 2(f) interpretation's one "holiday" example is a holiday club account, not a holiday gift. Its aggregation example: an item worth $7 for each quarter a NOW account's average balance exceeds $10,000 triggers the bonus rules, "since consumers are eligible under the promotion to receive up to $28 during the year."
This is information, not legal or tax advice. Check the current rule (or check with your compliance officer) before you send.
What Changes If a Gift Is a Bonus?
Two sections of Reg DD name bonuses:
"(7) Bonuses. The amount or type of any bonus, when the bonus will be provided, and any minimum balance and time requirements to obtain the bonus."
12 CFR 1030.4(b)(7), account disclosures. Read October 29, 2026.
"(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;" … "and (5) When the bonus will be provided."
12 CFR 1030.8(d), advertising. Read October 29, 2026.
The interpretation of 8(d) adds: "General statements such as "bonus checking" or "get a bonus when you open a checking account" do not trigger the bonus disclosures." And 1030.1(c) says "the advertising rules in § 1030.8 of this part apply to any person who advertises an account offered by a depository institution, including deposit brokers."
This is information, not legal or tax advice. Check the current rule (or check with your compliance officer) before you send.
Credit Unions: NCUA's Part 707
Reg DD's coverage line reads: "This part applies to depository institutions except for credit unions." NCUA's own Truth in Savings rule says: "This part applies to all credit unions whose accounts are either insured by, or eligible to be insured by, the National Credit Union Share Insurance Fund", with exceptions for corporate credit unions and certain small, nonautomated ones (12 CFR 707.1(c)). Its definition:
"(e) 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 member during a year in exchange for opening, maintaining, or renewing an account, or increasing an account balance. The term does not include dividends, other consideration worth $10 or less given during a year, the waiver or reduction of a fee, the absorption of expenses, non-dividend membership benefits, or extraordinary dividends."
"4. De minimis rule. Items with a de minimis value of $10 or less are not bonuses. Credit unions may rely on the valuation standard used by the Internal Revenue Service (IRS) to determine if the value of the item is de minimis. Items required to be reported by the credit union under IRS rules are bonuses under this regulation. Examples of items of de minimis values are: i. Disability insurance premiums on a share account valued at an amount of $10 or less per year. ii. Coffee mugs, T-shirts or other merchandise with a market value of $10 or less per year."
12 CFR 707.2(e) and Appendix C to Part 707, comment (f) (eCFR, up to date as of October 27, 2026). Read October 29, 2026.
NCUA's examples of what is not a bonus include "Discount coupons distributed by credit unions for use at restaurants or stores" and "$20 to any member if the member is responsible for encouraging a potential member to open an account", because "the $20 is not paid to the individual opening the account." Part 707 also leaves "non-dividend membership benefits" out of the bonus definition, defined as "any property or service provided by a credit union to its members, the nature of which makes its valuation unreasonable and administratively impracticable" (707.2(q)). NCUA's examples of those include prizes at annual meetings, which "are not bonuses because they are offered as an incentive to increase attendance at the annual meeting, and not to entice members to open, maintain, or renew accounts or increase an account balance."
This is information, not legal or tax advice. Check the current rule (or check with your compliance officer) before you send.
A Holiday Thank-You With No Account Condition: What the Texts Don't Say
Both definitions describe consideration given "in exchange for" account activity. We found no passage in Part 1030, Part 707 or their official interpretations that speaks to a thank-you sent to customers with no account condition attached, and we claim no exemption for one. The questions those texts leave for your compliance team:
- Is the gift offered or given "in exchange for opening, maintaining, renewing, or increasing an account balance", in words or in practice?
- Who receives it: holders of consumer accounts ("primarily for personal, family, or household purposes") or of business accounts?
- What is its "market value", and does the IRS valuation standard the interpretation mentions change it?
- What else has the same account received "per account per calendar year" under the same promotion?
- Does any advertisement or mailing mention a "bonus", and does the bank have a gift policy of its own?
This is information, not legal or tax advice. Check the current rule (or check with your compliance officer) before you send.
Can a Branch Pack and Ship Customer Gifts Itself?
Yes: a branch can assemble and ship customer gift boxes itself, and by our estimate 25 logo mug gift boxes take about 9 hours of hands-on work (about 3½ of them packing, at about 8 minutes a box), plus a week or more waiting for supplies from about 8 separate orders. Per box, it comes out about even: about $38 with USPS counter postage and about $34 with commercial postage, with $1,192.84 paid up front for the mugs, the retail supply packs and 25 postage labels (our DIY cost comparison, prices as of Oct 29, 2026).
A mug packed without a foam collar can break at the handle and must be bought, packed and shipped again, and a typo on 25 printed cards means printing 25 again.