Lobby Contest

One of our branches decided to do a contest for the customers (without clearing it with Compliance or Marketing, shocker). The first customer to walk in (or drive up) at 10,12, 2 and 4 were asked to participate in Christmas Movie Trivia for a chance to win a $10 gift card to a local restaurant. Apparently, every customer who participated one a prize. Is this an issue, other than the problem we have with the branch not checking with Compliance first?

Without knowing what your State sweepstakes/contest rules might be, it is hard to say. Just stop it and move on at this point. It is water under the bridge.

And tighten up your controls and procedures related to "branch promotions" i.e. what is allowable, what isn't, required disclosures, etc and provide training to all retail staff.