The bank is looking at offering 6 sets of our season football tickets in a deposit account promotion to all employees. I question the legality when I look at the lottery rules. The consideration in this instance would be the employee referring customers to open a new deposit account and greatest dollar volumes generated would win . My issue is that there is not a equal chance for all employees. Customer contact employees have more of an opportunity to qualify for entry than backroom employees. There contest outline does not have an alternative way for an employee to be entered into the drawing - to eliminate consideration.

Am I going in the right direction or over thinking the issue?

Employee incentive programs are not lotteries regardless of the rules.