Our eBranch is celebrating their 5 year anniversary next month. They are planning many things to celebrate this occasion - trips to each branch to meet customers who visit the branch etc. One of the things they are wanting to put together is a contest, possibly with our Facebook page. They haven't come up with a set idea yet, but had thrown out something to the effect of - if a customer/person likes our FB page, then they would be registered in a drawing for prizes. Of course this is not a monetary exchange but would it still be considered a lottery? And would it have to be open to everyone - not just our customers? I've been reading FDIC rules along with USC and I have also read our State Code which talks a lot about disclosures. I'm just not totally clear when it comes to social media use within the bank and what would technically be considered a lottery (if no cash is involved). Has anyone done a contest in this way? Any feedback/help would be appreciated!

Thanks so much!

Just an FYI - also check Facebook as I believe they have rules also.