Every year we do a bake sale to raise funds for Breast Cancer Awareness/Local Hospital Foundation. Is this acceptable?
We ran a contest and no prize was over $300. We didn’t need to collect non-public private information from the winners since the prizes were small, did we?
Is following the standard Regs, B, Z, DD and fair housing going to ensure advertising compliance?
Now that banks can participate in lotteries, can we facilitate raffles unrelated to the bank for local service groups- post lobby posters or sell tickets for or be a sponsor, etc.?
Can we do an internal raffle (selling tickets for a chance to win a prize) to benefit a non-profit organization?
We are trying to develop a Refer-a-friend program. We will offer a $50 bonus" for referring customer and a $50 bonus for the referred customer once the account is opened with direct deposit and they use a debit card a predetermined number of times in 60 days. We have a third party company that tracks referrals and bonuses which is trying to tell me I don't have to 1099 anyone because we're not paying the bonus at account opening - we're paying the bonus for meeting the qualifications of the program. Is a 1099 required for a $50 refer-a-friend bonus?
Can we advertise a drawing on social media only?
We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.
Most restaurants offer senior discounts now at about age 55 and so we want our Seniors Checking account product to be available at age 55. Our compliance officer said it violated Reg B, but then left the bank. This isn’t a loan product, so what gives?
If credit is denied because of issues related to only one applicant, for example a charge-off, can we disclose that reason to both applicants, and do both applicants get an Adverse Action Notice?