Legal Issues w/ Selling Bracelets on Teller Line

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Question:

We have been contacted by our community to sell bracelets on our teller line. The first 100 names of bracelets sold (the tellers would track the names) will go into a drawing for $500 cash. They say it will be open to anyone and not just our clients. Why else would the person be at our teller line if they were not our client? Also, they would like to give something special to the tellers for taking on this added work. I have no idea what "something special" is. We are an OCC bank and I have read through 12 USC 25a. I say that this is a raffle/lottery. Even though we would not be drawing the name of the winner, just selling the bracelets, to me this is still a raffle. Isn't it illegal in it self to allow the bracelets to be sold on bank property? This has nothing to do with deposits or our products or having to become a client of the bank. Would you agree?

Answer:

It's a lottery and 12 USC 25a forbids your bank's involvement. In addition, it's foolish to allow your employees to engage in any non-bank activity that distracts them from their assigned duties. I would take this opportunity to provide refresher training on the subject.

First published on BankersOnline.com 8/1/11