Our CEO is participating in a charity event and is considering notifying our customer base with an email blast which will include a link to donate. Is this allowed?

I think a better question would be- is this a good idea?

IMO it isn't

I had the same feeling but I checked with an outside audit firm and they said from a compliance perspective its no different that the donation cans placed at the teller window. The fact that we're using email doesn't change anything other than the fact that the email must comply with the Can Spam Act.

If you checked with the bank's shareholders, they might have a different view of an officer (even the CEO) using bank resources for personal reasons. Did your BOD approve this unusual activity?

BTW, these email messages would not be subject to CAN-SPAM because they do not meet the definition of a "commercial electronic mail message."

Potential reputational issue. Not all people think alike. There may be some customers that do not like the president's charity, strongly believe in a competing charity, or will be hurt if the bank does not support the future efforts of their personal charities.

IMHO, a can by the teller window is passive - an e-mail is active and intrusive.

I agree about this being a good idea for email. A personal call, contact would be better for several reasons.