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Cash Offer for Open Bill Pay-Fall Under Lottery?

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Question: 
Our marketing department wants to offer $20 for any customer who opens a new Bill Pay account and makes one payment online to receive the bonus. Does this fall under a lottery? Is this okay?
Answer: 

If every customer that does this gets the $20, it is not a lottery. There is no chance involved.

First published on BankersOnline.com 5/7/12

First published on 05/07/2012

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