The drawing is open to anyone who comes into the bank and has nothing to do with the referral of a settlement service, so I would not believe there would be a problem. Realtors should be allowed to place their own names in the drawing box when they visit the bank just like any other customer of the bank, whether or not they have ever brought or intend to bring an applicant into the mortgage area.
In my opinion, people in the mortgage department should not be allowed to place the names of realtors in the drawing. The realtors should place their own names in the drawing.