12/17/2012
At a recent Indiana Bankers Association Compliance Round table, we became concerned about our employee drawings for a charity. We offer drawings for prizes for first day donation, increased donation etc. We believe this may meet the definition of lottery but can't quite believe this activity would be prohibited. Please comment. We are a state chartered bank.
07/16/2012
Now that Reg Q is gone, what are the rules or what do we need to disclose if we want to offer a spin of a prize wheel (Prizes are from $25 - $200 ) for each new account opened? We are moving locations and would like to have this be part of our grand opening event.
08/01/2011
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?
01/24/2011
I would like to know if we would be out of compliance with Reg. Q and Reg D. if we do the following: our bank would like to advertise that a kid's club account with $100.00 would be given to the lucky winner who is drawn from customers who have registered. Also, if the customer already has an existing kid's club account, they would receive $200.00 added to their account if their name is drawn. Would this be allowed without having to issue a 1099?
08/09/2010
We want to sponsor a race to raise funds for local charities and to purchase school supplies for needy children. The entrants can pay a fee to enter. They'll get a shirt with the sponsors shown on it and we will pay a prize to the top finishers. Will we run into lottery problems with this arrangement or have other compliance issues?
05/03/2010
Our bank has a "Relay for Life" team and we will be doing several fundraisers to help raise funds for this. One fundraiser includes putting a picture of our three loan officers on separate containers. The one with the most money in it at the end will win the prize of a pie in the face. Customers and non-customers will be able to contribute to the loan officer of their choice. The pie thrower will be an employee of the bank. I just want to make sure we stay in compliance. Are we?
08/31/2009
We want to promote our Visa debit cards by having people "show us their debit card" and be entered for a Staples Gift Card drawing. If someone doesn't have our Visa debit card and we tell them if they sign up for one, they can be entered in the drawing. Are there any compliance concerns with this?
08/31/2009
Employees want to raffle off a savings bond, gold coins, etc. as a way to raise money for the local childrens' hospital. We think this is good for us and the community, and may even be good for CRA. My compliance sense tells me this may be a problem.
09/15/2008
My bank recently had to cancel a charitable event. Many of the items that had been donated for a raffle are time sensitive and we would like to auction them off before the reschedule date. We have developed a web page to auction these items from and are only inviting those people whom would have originally attended the charitable event to bid on the items. The auction page will in no way be associated with our bank's website. Do you foresee any regulatory, compliance or marketing issues with this?
06/09/2008
We are considering a giveaway in which customers will have a key to open a treasure chest and be able to scoop a child size shoe of quarters. What kind of compliance issues will we have?