Q. We have a checking account product that pays a high rate upon meeting several requirements. These include a direct deposit, 15 debit card purchases, and signing up for e-statements. If a customer is abusing the account (making 15 $1 or less debit card purchases in one day, setting up a direct deposit of just $5, etc.), can the bank close the account without risk of violating UDAAP? Our account agreement says that we can close an account for any reason. On the other hand, the customer is meeting all requirements the bank is advertising.
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