Thanks for the feedback Monster. I went ahead and approved the promotions on the condition that we included the below disclosures:
Promotion provided by "Bank". No purchase necessary to enter to win. Must be 18 years of age or older to submit an entry. Contest not open to employees of "Bank". All commenters will be entered into a drawing and the winner will be chosen randomly on “DATEâ€. Need not be present at drawing to win. Odds of winning will be determined by the number of entries received. Contest is in no way associated, sponsored, endorsed or administered by Facebook.
This disclosure includes most everything that the State requires except for the address of the bank. I figure if they are on our FB page, then they can find the address of the bank. It also includes a statement that FB is not involved at all, which is required by FB according to their guidelines. It seems like a lot to include in each post but our marketing dept said they could make it happen. And I have looked at a few other local banks that do similar things and they also include disclosures like this. So, I feel like we are ok to proceed. I did stress the fact that each post should be viewed by compliance before going live, just in case something new is added.