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#1837430 - 07/29/13 08:18 PM Lottery?
mll Offline
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Joined: May 2010
Posts: 131
How is this not a lottery?

Using your credit union visa and debit cards has always been convenient, but now you can be entered to win cash...just for using your cards. Now through the end of July we're giving away $100 every week.
Entering to win is easy:
1. Use your credit union visa or debit cards for purchases
2. Press CREDIT on the payment terminal and sign your transaction
3. Every time you swipe & sign, you're entered to win. It's that easy?"

"Enter as often as you like."

"Every week a new winner will be randomly picked and notified through the end of July."

"Be our next $100 weekly winner"

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#1837451 - 07/29/13 09:12 PM Re: Lottery? mll
rlcarey Offline
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rlcarey
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Galveston, TX
You sure there is not an alternate entry mechanism, if not, it's sounds like a lottery to me.
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#1837454 - 07/29/13 09:15 PM Re: Lottery? mll
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
Is there an alternate way to enter?
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#1837476 - 07/29/13 10:39 PM Re: Lottery? mll
mll Offline
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Joined: May 2010
Posts: 131
This is the only information I could see on their website. What 'alternate' way to enter, would make this okay?

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#1837482 - 07/29/13 11:03 PM Re: Lottery? mll
Kathleen O. Blanchard Offline

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Being able to enter by sending in a postcard to an address provided would open the contest up to anyone who wished to enter.
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#1837505 - 07/30/13 12:19 PM Re: Lottery? mll
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
What the alternate entry method (for someone who doesn't do business with the advertiser) does is morph the lottery into a sweepstakes. State laws on sweepstakes are a real patchwork, so you need to be careful about where you offer such a promotion and how it operates. But if you don't have the alternate entry method, you're looking at a lottery, and federal laws prohibit the participation of a bank or savings association in lotteries (there are not similar federal prohibitions for credit unions, as I recall).
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#1837865 - 07/30/13 09:07 PM Re: Lottery? mll
mll Offline
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Joined: May 2010
Posts: 131
Great information. Thanks everyone.

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#1837876 - 07/30/13 09:27 PM Re: Lottery? John Burnett
Matt_B Offline
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Matt_B
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A CU, Where Regs Don't Apply
Originally Posted By: John Burnett
(there are not similar federal prohibitions for credit unions, as I recall).


I'm not aware of federal prohibitions, but there are certainly still state laws to contend with!
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#1871949 - 11/17/13 11:30 AM Re: Lottery? mll
Andy_Z Offline
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Not to resurrect an "old" thread, but for discussion sake while I agree with Matt, what about the fact that Reg GG includes "lottery" in its definition of betting? CUs do not on a federal and at least some state levels (at lease that I have heard of) have a prohibition against lottery participation like banks, but how much of Reg GG would restrict a CU for participation?
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