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#2197790 - 11/08/18 05:39 PM Facebook Giveaway
LostinRegLand Offline
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Joined: Jun 2014
Posts: 82
WA
We are starting our path of using Social Media and will be starting with a Facebook page. To get our page out there and increase Likes to our page our Marketing Director is proposing to give a gift to any customer that can show to a teller that they have liked the Facebook page. I will be delving into what type of gift and value of gift at a meeting this afternoon but I need to know what rules, regulations, etc I need to be concerned with so I can bring up any concerns then. Social Media is new to us and from compliance I want to make sure we are doing everything right.

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#2197795 - 11/08/18 05:55 PM Re: Facebook Giveaway LostinRegLand
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,622
It all depends on the specifics of the giveaway. If there is any "chance" involved in the prize, then you might have a lottery on your hands which is prohibited here: https://www.fdic.gov/regulations/laws/rules/1000-2200.html. (State law could also have impact.)

If there won't be any "chance" in the prize, then it shouldn't be too big of a deal though typically EHL and member FDIC rules apply as well as possible bonus/IRS implications depending on the size of the gift. You should also be aware of FB contest rule as they have limitations on shares and tags.

I actually just published a (free) video on Facebook contest considerations that might give you a few things to think about, so I will PM you the link.
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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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#2197797 - 11/08/18 06:06 PM Re: Facebook Giveaway Adam Witmer
LostinRegLand Offline
Member
Joined: Jun 2014
Posts: 82
WA
Thank you. I would appreciate the link. I have already looked at the FDIC rules on lottery and do not believe that there is any chance involved.

It is the size of the gift that has me worried and I am hoping to get a better picture of that at the meeting this afternoon. I will look into the Facebook rules.

All good areas for me to concentrate on.

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#2200902 - 12/17/18 07:25 PM Re: Facebook Giveaway LostinRegLand
praBSA Offline
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Joined: Aug 2018
Posts: 334
I am wondering what your outcome was. I am not a marketing guy but I was asked today if we could give away a $25 gift card to those whom login to our website and take educational training or visit a particular page on our website. I am wondering if there are an UDAAP concerns or rules that would prevent this? If anyone has any input on where to begin, it would be greatly appreciated. There is no chance involved, every customer is eligible.

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#2200912 - 12/17/18 08:27 PM Re: Facebook Giveaway LostinRegLand
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,284
Galveston, TX
every customer is eligible

It would to be available to more than customers. Then what ever action they are engaging in to earn a chance to win would have to be looked at to see if it qualified as consideration.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2200914 - 12/17/18 08:43 PM Re: Facebook Giveaway LostinRegLand
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,622
Randy, I don't think it would need to be available to more than customers if there is no chance involved, as praBSA stated. I haven't seen this done before (which is always a risk flag) and don't know the particulars of the proposed giveaway, but wouldn't this be similar to giving a bonus for opening a new account?
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2200915 - 12/17/18 08:49 PM Re: Facebook Giveaway LostinRegLand
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,284
Galveston, TX
I may have misread that post. If everyone that does X gets the $25, then I agree.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2200951 - 12/18/18 03:00 PM Re: Facebook Giveaway LostinRegLand
praBSA Offline
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Joined: Aug 2018
Posts: 334
Correct. We do not allow account openings online, but we were considering allowing all customers the opportunity to obtain say a $20 gift card or equivalent by completing tasks while logged into their account to get them more familiar with our new online banking. My concern was more with customers whom may not use the internet due to age or customer's whom flat out do not have internet if such a bonus would be considered in any way discriminatory. Maybe the fact that I am asking the question means I am answering my own question? I am just thinking out loud at this point.

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