One of our MLOs is advertising "enter to win" by leaving a business card in a bowl at a local café. The winner will receive a gift card to the café. I don't have any concerns about the contest, since the ad contains the proper disclosures required by State law.

Should I have any other concerns??

The MLO is creating the drawing?

If so, what do people have to do to enter? Simply leave their business card? If so, this isn’t a lottery.

Yes and yes......leave your business card at the café and a drawing will take place at the end of the month. Seems harmless, but when it comes to MLOs giving things away I get nervous.

What is the LO trying to accomplish by giving away the gift card?