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#145915 - 01/06/04 07:28 PM Home show coupon / drawing
Bartman Offline
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Bartman
Joined: Oct 2000
Posts: 1,191
Springfield
New proposal from the mortgage department - I'd like some reassurance that I've analyzed this correctly:

Home show season is approaching, and the bank would like to increase traffic at our information booth by holding a drawing. The "prize" may be a coupon for $500 off closing costs. (Another alternative - EVERYBODY wins a coupon, but in differing amounts based on a random drawing...one $500 winner, 10 $250 winners, 50 $50 winners, others $25, for example.) Entrants fill out name, address, phone, email & drop the card into a container for the end-of-show drawing. Originators later follow up by phone or mail / email to generate possible leads.

Further, the home show organizers are producing flyers to be handed out at the show - one proposal is to print drawing entry cards on the flyers, to draw people to our booth.

I don't see a RESPA section 8 issue here, because the flyer printing is paid for through our booth fee - they'll be printed & distributed to all participants whether we request something on them or not. Likewise, the "prize" goes to the potential applicant directly, so there isn't a referral of settlement services by any other party.

The drawing will be open to anyone, with no purchase necessary.

Privacy isn't an issue as long as we do not sell the list of names generated from the drawing, although a disclaimer of our intent to contact them later might be a prudent addition.

Not clear on the email followup piece yet in light of CAN-SPAM - do we need any kind of disclaimer on the entry tickets giving us permission to email?

What else did I miss?
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Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."

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#145916 - 01/06/04 07:37 PM Re: Home show coupon / drawing
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 82,999
Galveston, TX
Quote:

Privacy isn't an issue as long as we do not sell the list of names generated from the drawing, although a disclaimer of our intent to contact them later might be a prudent addition.





If you don't do this, make sure you run the names against the do not call lists prior to making these phone calls.
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#145917 - 01/07/04 04:49 PM Re: Home show coupon / drawing
wavewatcher Offline
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wavewatcher
Joined: May 2003
Posts: 2,053
Hawaii
Quote:


Not clear on the email followup piece yet in light of CAN-SPAM - do we need any kind of disclaimer on the entry tickets giving us permission to email?

What else did I miss?




I presume you would be sending a blind e-mail blast to all entrants, I would also include on the e-mail that they can ask to be deleted from the e-mail if they don't want to receive further e-mails from you.

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#145918 - 01/09/04 03:32 PM Re: Home show coupon / drawing
Al Miller Offline
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Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
One could possibly argue that the admission fee to the show is a "cost" to enter and that would make it a lottery. Have an alternate entry method available for those who do not attend but somehow hear there is a drawing.
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#145919 - 01/09/04 04:04 PM Re: Home show coupon / drawing
Bartman Offline
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Bartman
Joined: Oct 2000
Posts: 1,191
Springfield
Al - good catch, and thanks. I think it's a free event, however.

Thanks, too, for the other comments.
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Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."

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#145920 - 01/09/04 09:52 PM Re: Home show coupon / drawing
wavewatcher Offline
Diamond Poster
wavewatcher
Joined: May 2003
Posts: 2,053
Hawaii
Quote:

One could possibly argue that the admission fee to the show is a "cost" to enter and that would make it a lottery. Have an alternate entry method available for those who do not attend but somehow hear there is a drawing.



I never thought about that aspect. We also use a similar marketing tool to our home shows, entry blanks are available both outside and inside the home show. Outside where you buy your ticket to enter the show. Inside is where you deposit your entry blank for the drawing.

Should we worry about this?

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