Here we go again.....another promotion on Facebook question.

My marketing department is asking me if it would be alright to do a weekly giveaway from our Facebook page. Basically, we would offer a small gift on a certain day each week. What they are suggesting is to ask a question each week (not necessarily a question that has to be answered correctly, ex. Do you love snow?) and the winner would be selected randomly from all that commented on the post. I've read the Facebook rules and our State guidelines. I guess my question is - would each disclosure required by FB and the State be required in each weekly post? It seems like a lot to include for a small giveaway on social media, but I assume it would be required. Is there another way to post these disclosures separately? Also - would it be stretching it to say, requiring a person to comment on the post to have a chance to win, is a consideration?

Does anyone else do anything like this and if so how do you handle all of the guidelines?

Thanks!

I'm not familiar with the facebook or state rule you mention, I would assume it depends on FB and the state's rule. Though, I've had something like this come up previously and I reached out to our state regulator who 'blessed' the idea, but our state didn't have any specfic rules like it sounds like yours does.

Our state regulator didn't feel a comment was consideration.

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 “DATE”. 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.

Thank you.