01/05/2025
Our debit card vendor, TransFund, is doing a 50th Anniversary giveaway to its cardholders. In order for our cardholders to be eligible, we have to register our bank for the giveaway. If we do register our bank, every time our cardholders use their TransFund debit card for a qualifying purchase, they are automatically entered to win. TransFund will be awarding a $1,000 winner each month, qualifying them to win their choice of a new car, valued up to $50,000. In addition, TransFund will be giving away $500 per month to a qualifying cardholder who uses a TransFund ATM.
TransFund is calling this a sweepstakes, but wouldn't this be considered a lottery? Can our bank register for this and then market it to our customers? I'm having a hard time understanding why a debit card vendor that does business with hundreds of banks in different states would put them at risk with the law by offering a lottery to its customers. I'm hoping my understanding of a lottery is just wrong. Any guidance you can give me, would be greatly appreciated.
11/24/2024
If we feel that a debit card holder may be heading towards becoming a collections account due to excessive state lottery and state liquor store transactions on a daily basis, can we restrict the card from being used at those MCC transaction types?
05/08/2022
Can we email our online customers with a survey and entice their opinions with a drawing (4 winners will receive $250)? Only customers are contacted but only our online customers have opinions on our online banking. Can we do this activity or does it fall under "lottery" prohibitions?
10/25/2020
Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer?
Examples would be:
1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket.
2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets.
3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.
05/10/2020
What do 'giveaways' fall under? sweepstakes or contents?
04/12/2020
We want to promote debit card usage and management wants to have a monthly drawing for a $25 gift card. I think that this is not permitted since it would not allow non-customers to enter and bank customers with debit cards are the only ones who can win - am I correct?
We have seen other banks do this in our area, so management thinks it is just fine.
09/17/2017
We want to do a promotion/fund raiser at a festival for our local food bank. We will be promoting our new Popmoney product. The idea is that we will have a wheel to spin with 36 varying amounts on the wheel from $1.25 up to $15. Festival attendees will be allowed an opportunity to donate $1 to the food bank for a chance to spin the wheel. Every spin will win at minimum $1.25 which we will then send to the individual via popmoney. We will set a $750 maximum giveaway limit for the festival, and when we reach that amount, we will shut down the event. All of the $1 donations will be given to the food bank and we will completely fund the amounts given to the participants, including the fee for each popmoney transaction. Based off what I have read on the Federal Deposit Insurance Act Sec 20, lottery is defined by "the advance of money or credit in exchange for the possibility or expectation
that one or more BUT NOT ALL of the participants will receive by reason of their advances more than the amounts they have advanced". Since all participants would receive more than they advance this would not be a lottery correct? If I am correct are there any other issues I have not considered?
03/30/2015
I am hosting a medical benefit for a friends little boy. We both are employees of a bank in central Illinois. For the event I would like to have a 50/50 and gun raffle with tickets available for purchase from the branches of our bank. Could you answer whether or not that is acceptable or point me in the direction of what Reg. I need to look into to get my answer. They bank would not be sponsoring the drawings just hosting sign up.
01/19/2015
I know banks cannot advertise or promote a lottery or raffle but can an employee who is involved in a non-profit organization sell raffle tickets to other employees on bank property?
05/20/2013
What is the banks responsibility when they receive a freeze from the lottery commission?