With proper disclosures, you should be able to provide the account bonus on the condition that the customer enrolls in internet banking. Any advertising and account disclosures should clearly state that customers must sign up for internet banking to receive the bonus. 

If you will not be providing paper statements to the customers that enroll in internet banking, note that both Illinois and federal law require you to obtain the customer’s consent and provide certain disclosures before enrolling the customer in electronic statements. Those disclosures must include “any conditions, consequences (which may include termination of the parties’ relationship), or fees” that would apply if the customer does not consent to electronic disclosures, such as the fact that the customer would be disqualified from receiving the account opening bonus. 

In addition, because this bonus is directed only to students under the age of 25, we do not see any UDAAP concerns with conditioning the bonus on access to internet — although this analysis would likely change if the accounts instead were directed at senior citizens. 

For resources related to our guidance, please see below: 

• Electronic Signatures in Global and National Commerce (E-SIGN) Act — 15 USC 7001(c)(1) (consent requirement); 15 USC 7001(c)(1)(B)(i)(II) (disclosure of conditions, consequences, and fees)

• Illinois Financial Institutions Electronic Documents and Digital Signature Act — 205 ILCS 705/10(c) (consent requirement); 205 ILCS 705/10(c)(1)(B)(i)(II) (disclosure of conditions, consequences, and fees)