What do 'giveaways' fall under? sweepstakes or contents?
We want to promote debit card usage and management wants to have a monthly drawing for a $25 gift card. I think that this is not permitted since it would not allow non-customers to enter and bank customers with debit cards are the only ones who can win - am I correct?
We have seen other banks do this in our area, so management thinks it is just fine.
We want to do a promotion/fund raiser at a festival for our local food bank. We will be promoting our new Popmoney product. The idea is that we will have a wheel to spin with 36 varying amounts on the wheel from $1.25 up to $15. Festival attendees will be allowed an opportunity to donate $1 to the food bank for a chance to spin the wheel. Every spin will win at minimum $1.25 which we will then send to the individual via popmoney. We will set a $750 maximum giveaway limit for the festival, and when we reach that amount, we will shut down the event. All of the $1 donations will be given to the food bank and we will completely fund the amounts given to the participants, including the fee for each popmoney transaction. Based off what I have read on the Federal Deposit Insurance Act Sec 20, lottery is defined by "the advance of money or credit in exchange for the possibility or expectation
that one or more BUT NOT ALL of the participants will receive by reason of their advances more than the amounts they have advanced". Since all participants would receive more than they advance this would not be a lottery correct? If I am correct are there any other issues I have not considered?
I am hosting a medical benefit for a friends little boy. We both are employees of a bank in central Illinois. For the event I would like to have a 50/50 and gun raffle with tickets available for purchase from the branches of our bank. Could you answer whether or not that is acceptable or point me in the direction of what Reg. I need to look into to get my answer. They bank would not be sponsoring the drawings just hosting sign up.
I know banks cannot advertise or promote a lottery or raffle but can an employee who is involved in a non-profit organization sell raffle tickets to other employees on bank property?
What is the banks responsibility when they receive a freeze from the lottery commission?
At a recent Indiana Bankers Association Compliance Round table, we became concerned about our employee drawings for a charity. We offer drawings for prizes for first day donation, increased donation etc. We believe this may meet the definition of lottery but can't quite believe this activity would be prohibited. Please comment. We are a state chartered bank.
Now that Reg Q is gone, what are the rules or what do we need to disclose if we want to offer a spin of a prize wheel (Prizes are from $25 - $200 ) for each new account opened? We are moving locations and would like to have this be part of our grand opening event.
We have been contacted by our community to sell bracelets on our teller line. The first 100 names of bracelets sold (the tellers would track the names) will go into a drawing for $500 cash. They say it will be open to anyone and not just our clients. Why else would the person be at our teller line if they were not our client? Also, they would like to give something special to the tellers for taking on this added work. I have no idea what "something special" is. We are an OCC bank and I have read through 12 USC 25a. I say that this is a raffle/lottery. Even though we would not be drawing the name of the winner, just selling the bracelets, to me this is still a raffle. Isn't it illegal in it self to allow the bracelets to be sold on bank property? This has nothing to do with deposits or our products or having to become a client of the bank. Would you agree?
I would like to know if we would be out of compliance with Reg. Q and Reg D. if we do the following: our bank would like to advertise that a kid's club account with $100.00 would be given to the lucky winner who is drawn from customers who have registered. Also, if the customer already has an existing kid's club account, they would receive $200.00 added to their account if their name is drawn. Would this be allowed without having to issue a 1099?