I absolutely love the ATM $50 idea and my first thought was this: "Where is this bank as I would gladly pay their ATM fee for the chance to win the extra $50! In fact, I may just have to take out several withdrawals...just like I was playing the lottery!"
So, even though I LOVE this creative idea...
Unfortunately, I think you are going to have a problem with this, because of the definition of a (prohibited) lottery:
(2) The term "lottery" includes any arrangement, other than a savings promotion raffle, whereby three or more persons (the "participants") advance money or credit to another in exchange for the possibility or expectation that one or more but not all of the participants (the "winners") will receive[/b[ by reason of their advances [b]more than the amounts they have advanced, the identity of the winners being determined by any means which includes-
(A) a random selection;
(B) a game, race, or contest; or
(C) any record or tabulation of the result of one or more events in which any participant has no interest except for its bearing upon the possibility that he may become a winner.
Paying an ATM fee for the chance to get a $50 instead of a $20 seems to perfectly fit the definition of a lottery - which, unfortunately, is prohibited.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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