IBA Compliance Connection

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We want to gift iPad minis to borrowers who are eligible for secondary market financing and close a home purchase or a home refinancing loan. Do we need to disclose the value of the gift in our marketing? Are there any disclosures related to the gift that we must provide the customer?

Mar 31, 2015

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No, we do not believe Regulation Z’s closed-end credit advertising rules would require you to disclose the value of the gift, and we are not aware of any other disclosure requirements that might apply to such gifts. In addition, we note that you will not have to report the gift on IRS Form 1099-MISC if the value of the gift is below $600.

For citations related to our guidance, please see below:

Regulation Z — 12 CFR 1026.24 (Advertising for Closed-End Credit)

IRS Webpage, Form 1099-MISC