We have a CSR who has asked if he can start a football pool for our employees. My HR isn't concerned about this, but wanted to check it out with Compliance - I just don't think this is a good idea at all.

Any thoughts would be appreciated.

Basketball and Football pools are common place in the work place, especially when they are for a nominal amount. Always a good idea to have upper management included in the pool.

^^ sarcasm?


I would avoid the pool if possible. Or, at the very least, make it well known that the pool is NOT an employer-sponsored event. Have employees communicate using their personal email addresses instead of their bank ones.

We have had football, March Madness brackets, and do a pool with the Survivor show as well. Management's stance has been that as long as it does not interfere with work time and doesn't utilize company resources (email or intranet for results posting etc) they will let it continue. I'm still not really a fan of it, but we don't seem to have a problem with people breaking those rules.

As Compliance Officer, I always avoided (since they are technically not legal), but I looked the other way as long as nobody was taking too much time from their job or using company resources to support the pool.

Similar discussion and thoughts from a few months ago...

Just to add to this, we had examiners here in March and had a March Madness pool going on. Naturally, I thought they were going to nail us to the wall for having a pool. Instead, they wanted to know who was winning and how to get in and no, that wasn't a test.

I think even examiners know people need a little, harmless release from their jobs.

My example in that other thread is a real life example. On bank time and on bank computers employees were keeping the pool spreadsheet, it was huge. Money was in an interest bearing account and audit kept all of the records. Bank email was used to send around updates. The entire bank participated, as well as their families and customers! Aggghhh. And this was in a state that has shut down such pools and arrested people.

We (me and legal) shut it down and told them if some employees (outside of audit, risk, compliance and legal) did this informally on their own time, staff only, we would look the other way. A little sanity is nice once in a while.

Truth is stranger than fiction.

I know I am a little late to this thread, but take a look at your regulators rules on this. If money is required to enter the "pool," then this is a lotter and forbidden. Also, as KB said, many states also prohibit this and are very active in enforcing it.

Here is the link to the FDIC's rules: http://www.fdic.gov/regulations/laws/rules/1000-2200.html

As long as no one is getting a cut or "juice" as they say in the betting world, it's not going to be a problem. Keep the entry fees low.

I would say that nearly every bank in Kentucky has a Kentucky Derby pool amongst it's employees.

^^ My stance as well. Management can't condone this. It is an illegal activity as it meets the definition of a lottery. But it is going to happen. It is like going 5 MPH over the limit, it's a minor infraction. If it gets big, uses bank resources, or is openly boasted about, that is a problem and they're now 15 MPH too fast.

So, any big winners on your "illegally" obtained squares??