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#2180759 - 06/05/18 05:17 PM Social Media Contest
mnbanker09 Offline
100 Club
Joined: Jan 2018
Posts: 128
Our marketing department is considering a contest on social media which includes language for the user to ‘like’ our page which enters them in a contest to win a prize. Outside of the Facebook, Instagram and other social media guidelines and rules, I am looking for regulatory guidance on this type of advertising. Are prize giveaways allowed in this capacity? What other considerations do we need to be aware of? Thanks in advance for your feedback!

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#2180774 - 06/05/18 06:08 PM Re: Social Media Contest mnbanker09
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
General advertising rules apply to social media advertisements. In addition, you must make sure it doesn't become a lottery. Also, each state has different requirements for lotteries and sweepstakes, so you need to check your state specific laws.

(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 by reason of their advances 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.

(3) The term "lottery ticket" includes any right, privilege, or possibility (and any ticket, receipt, record, or other evidence of any such right, privilege, or possibility), of becoming a winner in a lottery.

(4) The term "savings promotion raffle" means a contest in which the sole consideration required for a chance of winning designated prizes is obtained by the deposit of a specified amount of money in a savings account or other savings program, where each ticket or entry has an equal chance of being drawn, such contest being subject to regulations that may from time to time be promulgated by the appropriate prudential regulator (as defined in section 5481 of this title).
_________________________
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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#2215180 - 06/06/19 06:54 PM Re: Social Media Contest Adam Witmer
Newbie06 Offline
Platinum Poster
Joined: Mar 2006
Posts: 731
So, if we wanted individuals to like our page for the chance to win a bank lunch box with some bank related prizes in it (lip balm, t-shirt, stress ball, etc...) we would need to post contest rules in order to technically be in compliance?

After reviewing other bank's FB pages I don't see a lot of FI's doing contests on-line.

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