12/10/2007
We routinely send out customer surveys to our retail customer base. We urge them to complete and return the surveys to us postage paid. We tell them that by completing and returning the survey, they will be entered in a drawing to win a Starbucks gift card. Do we run afoul of any compliance rules?
01/22/2007
We do a monthly newsletter and in the month of December, we raffle off a tray of cookies to a customer. Is it compliant for us to announce the name of our cookie winners in our newsletter, or is this a breach of privacy? The newsletter goes out to all customers.
01/02/2007
Are OTS regulated savings associations held to the lottery rules like national banks and state banks? If so, can you cite the reg/statute?
05/01/2006
Our Bank is considering a promotion that would allow a new customer to select their bonus (premium-$5-$100) for opening a free checking account (no minimum balance, no time requirement). This bonus will be printed on various slips of paper and placed in a container from which the customer will select. Do we have any compliance issues? Is this considered a sweepstakes?
07/18/2005
We have been asked to be a ticket outlet for a Chamber of Commerce event. Are there any operational or compliance issues that would prohibit this?
05/16/2005
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?
05/02/2005
Our bank has a Relay for Life Team and we are planning fundraisers. Can the team sell tickets/chances for a prize? Not tied to any banking product and not paid for by bank. This is strictly a charitable fundraiser but would be conducted within the bank. We are a state member bank of the Federal Reserve.
05/02/2005
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?
11/01/2004
As a national bank, I am aware that we are prohibited from dealing in lotteries and related activities. The definition of "lottery" refers to an advance of money or credit with an expectation.... To bring in new business, the retail division wants to visit with the employees of current business customers and invite them to open an account. If there is no exchange of money, just names or business cards placed in a bowl, for instance, with a drawing for a gift basket to go to the winner, and this is open to all with no requirement to open or maintain an account, do you think this would be allowed?
09/20/2004
Is there any problem having a "contest of skill" that could earn a customer a lower finance rate or a higher interest rate? We want to give any customer who wants three tries to "sink a putt" in a makeshift golf green that we are setting up in our newly renovated lobby. If they make the putt, they get either 10 basis points less on a loan or 10 basis points more on a CD.