Well, I don't think this would be permitted as you describe it. To explain, let's look at the definition of a lottery (this is from FDIC rules):
(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.
In reviewing your proposal, I see two things. First, the essay is about why customers love your bank. This implies that only customers can submit the essay (though I could be wrong), and when you have a customer, they have advanced money (opened a deposit account) or advanced credit (taken out a loan). Secondly, a contest to determine the winner is included in the definition of a lottery. Therefore, it appears your proposed "contest" meets the definition of a lottery (under the quoted FDIC rules) and, therefore, is not permitted.
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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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