That's what I thought.
So many strict prohibitions when we're trying to do good.
I've reviewed the OCC's 2015 IL 1153. THat has to do with a weight loss incentive for bank employees, but the author of the IL offers the following:
“The policy rationale behind the lottery prohibition is that financial institutions should not be used to encourage vulnerable members of society to waste their money through gambling. The legislative history shows that Congress was focused on the sale of state lottery tickets at financial institutions and the evils of gambling. In a May 11, 1967, letter to Comptroller of the Currency William B. Camp, one congressman complained that it was “inconceivable to permit the use of thrift institutions as bookie parlors.” Congressman Patman, the primary sponsor of the legislation, stated that it “was brought about in response to the dangers arising from a new lottery voted into existence by the State of New York.”
Clearly, trying to raise money for charity is not 'evils of gambling' as seen through the lens of 1967 legislators ...