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#1197486 - 06/08/09 07:14 PM Special Drawing for Cool Prize
Anonymous
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I've been presented with material from another bank that offers an account "for young people from 13 to 19 years of age" that also promotes "every quarter during the year, there is a special drawing for a really cool prize (no purchase necessary.)" I've been requested to create a competing account for our bank with similiar standards.

My knee-jerk reaction is to say this is a lottery or raffle, and therefore not possible, but obviously the other bank is doing it so the thought is we should be able to as well (and if the other bank jumped off a cliff...) Since the request is from a board member I want to make sure I've researched this thoroughly before replying to them.

Does this sound like a raffle/lottery? Is there a "loop hole" that I'm missing? And IF we're able to do this - would the "cool prize" fall under a bonus rule since there is interest on savings accounts?

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#1197498 - 06/08/09 07:23 PM Re: Special Drawing for Cool Prize Anonymous
RR Joker Offline
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The Swamp
If you have to be an accountholder (consideration) to be eligible, then I don't see any loopholes right off.
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#1197515 - 06/08/09 07:35 PM Re: Special Drawing for Cool Prize RR Joker
Phoenix Offline
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Joined: May 2003
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southeast
any parental consent needed? (thinking COPPA, if any online publicity is involved)
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#1198563 - 06/10/09 02:00 PM Re: Special Drawing for Cool Prize Phoenix
Anonymous
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Called the bank - to be a part of the quarterly drawing - an entry form needs to be picked up at the branch. The drawing is open to anyone between the ages of 13-18 (that's the "no purchase necessary" part), but essentially - if your not a bank customer, you don't really know about it b/c it's not something publicized outside of the bank - except for the the one line referencing it in the product write up - which tells you to talk to a service rep for more details.

To me - it sounds like they are meeting the legal requirements for it NOT to be considered a raffle/lottery in that technically it is open to everyone, but that customers are alloted a better chance of winning since they are "in the know". Is it just me - or does this sound like compliance "grey zone"?

My board meeting is in 5 business days. Right now, I say this is a bad idea to try to duplicate. Any other thoughts?

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#1198567 - 06/10/09 02:05 PM Re: Special Drawing for Cool Prize Anonymous
Skittles Online
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TN
I do, too. What does your bank hope to gain by duplicating another bank's promotion?
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#1198587 - 06/10/09 02:21 PM Re: Special Drawing for Cool Prize Skittles
Anonymous
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Originally Posted By: Duchess Skittles
I do, too. What does your bank hope to gain by duplicating another bank's promotion?


To clarify - it's not a promotion, they have the drawing built into the account as an ongoing perk.

From time to time, members of our board get a "me too" mentality. They see a product or service another bank offers that we don't & feel we have to have it too to be "competetive". It doesn't help with compliance issues that our board's favorite phrase is "well, everyone else seems to be able to do it." Although we offer youth accounts, they are not a "best seller" & new accounts are being asked to increase sales in this area. This particular board member is suggesting we incent with something like the quarterly drawing & offer iTunes downloads. I understand where our board is coming from - but anything with a drawing sets my Spidey senses tingling. (Boy, I'm glad this is an Anonymous!)

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#1199366 - 06/11/09 01:36 AM Re: Special Drawing for Cool Prize Anonymous
complyyes Offline
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Joined: Apr 2006
Posts: 51
Midwest
Our bank opens all drawings by stating that mail-in entries are accepted, I talked them into this so that it was not a lottery but a legitimate drawing. We give the how to, where to, by when to, info in the disclosure. Our odds of winning rely on the number of entries including mail in. Obviously, we add those mail in names to the drawing pot. Basically, the entries are to those who open student accounts but with this caviot it works and the senior management is happy that they have an awesome drawing for the students. Few mail-in but they are always welcome.

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#1199387 - 06/11/09 11:42 AM Re: Special Drawing for Cool Prize complyyes
rlcarey Online
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Galveston, TX
Prior to spending money on attracting or maintaining student accounts, I would be taking a hard look at the statistics on average account balances/profit and the percentage of kids that remain in the home town after graduation. It use to be: get them young and you had them for life. Now, marketing money most likely can be spent on better endeavors.
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#1199906 - 06/11/09 06:47 PM Re: Special Drawing for Cool Prize complyyes
Anonymous
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Great idea - thank you!

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#1199915 - 06/11/09 06:55 PM Re: Special Drawing for Cool Prize rlcarey
Anonymous
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Ok - the great idea was referencing the mail-in entries.

As for the "hard look" - that's easier to say when you're not working here. Not that I don't agree with the concept - I just know the reality in which I must work. But thank you, too, for your input. I appreciate your time & consideration of our issue.

Originally Posted By: rlcarey
Prior to spending money on attracting or maintaining student accounts, I would be taking a hard look at the statistics on average account balances/profit and the percentage of kids that remain in the home town after graduation. It use to be: get them young and you had them for life. Now, marketing money most likely can be spent on better endeavors.

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