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Social media use by proxy

Can a bank be liable for encouraging employees to solicit responses to a contest benefitting a local charity with links posted on their personal social media pages?

If the "contest" is a lottery or raffle or constitutes gambling (which may be illegal in your state), then the answer is yes -- the bank could potentially have liability for encouraging employees to be involved. Under existing banking laws each regulatory agency (OCC, FDIC, FRB) prohibits the bank from participating in a lottery, with one limited exception for savings accounts.

Learn more about Andy Zavoina’s Social Media Compliance Requirements webinar.

First published on 11/27/2022

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