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#1058132 - 10/03/08 07:14 PM Bank employee drawing
complyyes Offline
Member
Joined: Apr 2006
Posts: 51
Midwest
We solicit donations from our employees every year for the United Way Campaign. This year they want to give tickets out for drawings & prizes. If you donate $ you get one ticket, if you donate $$ you get 6 tickets and so forth. Should everyone in the bank get one ticket regardless of donating? Is this permissible or does it fall under the term "lottery"?

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#1058139 - 10/03/08 07:19 PM Re: Bank employee drawing complyyes
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,228
Galveston, TX
Sounds like all the makings of a lottery to me.
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#1119831 - 01/30/09 02:46 PM Re: Bank employee drawing rlcarey
Tesla Offline
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Joined: Nov 2003
Posts: 3,726
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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#1119994 - 01/30/09 04:12 PM Re: Bank employee drawing Tesla
David Dickinson Offline
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David Dickinson
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Posts: 18,762
Central City, NE
First, section 20 of the FDI Act prohibits banks from doing ANYTHING with lotteries. It doesn't say anything about employees or customers.

Technically, I don't think this is a problem. The definition does say they have to give "consideration". It say they must "advance money or credit".
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David Dickinson
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#1120021 - 01/30/09 04:25 PM Re: Bank employee drawing David Dickinson
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,228
Galveston, TX
"We have a vendor who will pay the Bank $X/quarter if certain goals are met."

However, depending on what this vendor is involved with, there may be other considerations.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1120113 - 01/30/09 04:56 PM Re: Bank employee drawing rlcarey
Tesla Offline
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Joined: Nov 2003
Posts: 3,726
Thanks Randy and David.
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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.

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