Our retail services department is wanting to start a promotion for opt in with debit cards in regard to opting in for overdraft services. To encourage our employees to have these conversations with the customers, they want to have an employee contest. Something along the lines of who ever gets the most customers to opt it at each branch will have their name drawn for a prize or the branch that gets the most opt ins will get lunch provided by the bank. Can we do this? My thoughts are that examiners will not like this because of possible steering. Am I going overboard on this?

To avoid steering if you are going to go with a contest such as this, you are better served with offering the same incentive whether a customers opts in or opts out. (I still don't recommend it.)

Here's the consequences of misrepresenting overdraft opt-ins to win a contest.

https://www.consumerfinance.gov/abo...king-consumers-costly-overdraft-service/

Thank you for sharing this information Brian. I agree I don't think we need to go down this path.