Our Marketing department has proposed a holiday promotion where we exchange some of the $20s in the ATM for $50s. The idea is that we draw attention to our bank, keep traffic out of the teller line, and save on over the counter transactions. It, of course, would be open to anyone with a debit card, not just our customers. This may be nightmare for the folks that have to balance, but speaking strictly from a compliance perspective, can anyone think of any issues in doing this? Thank you.

Marketing may need to rethink that. I have a debit card with a $10,000 limit and I will drain the cash in your ATM in a flash. Even if I only had a $300 limit, I would stop by every day, take my $300 out of the ATM and then walk into the branch and make a deposit, thus increasing traffic.

The marketing department has decided to move forward with this promotion. Does anyone have advice on what all disclosures should be included with the advertising? I'm thinking:

1. Open to anyone with a valid debit card from any banking institution
2. Standard debit card fees may apply
3. Odds of winning depend on the number of debit card transactions

We don't need any hold harmless language, do we? Thanks in advance!

I am surprised that your marketing department decided to move forward with this... Using rlcarey's example is just one justification to not go forward with this. But im sure at your FI, like mine, Marketing carries the bigger stick.

I would ensure that security at the ATM area has been reviewed, lighting, cameras. Ideal place for robbery, you know that most people are going to take out more than usual because of promotion.

Also there is threat of employee theft, unsure how you fund atm, my FI, dual control two employees, but there could easily be collusion,

example, supposed to put one hundred $50 bills instead of one hundred $20 bills. Me and my fellow employee take fifty $50 bills and replace with fifty $20 bills of our own money.... no one would ever know. employees split profit 50x30=$1500 $750 each

Or the employees know where the money is in the stack.

As far as other hold harmless disclosures, your crackerjack marketing department (or should I say crackpot ) should have already vetted this promotion through your legal department to make sure that they meet all State sweepstakes and other legal requirements. The real question is this a lottery since no everybody gets a "prize"?

-LauriA

Curious as to how the promotion went, smoothly? any problems?