Just to clarify, even if the "lottery" is part of an incentive program for employees (no outsiders involved), it is an illegal lottery for compliance purposes?
We have a vendor who will pay the Bank $X/quarter if certain goals are met. The Bank wants to put an employee's name in a hat if they do something (consideration) and then once a quarter draw a few winners. Am I to understand this is not permitted? If so, how big a regulatory risk is this?
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It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.