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How to Promote E-Statements w/ Cash Drawing

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Question: 
We want to promote e-statements by having a cash drawing in Dec. for those who sign up and have an active account. How do we proceed and be compliant and it not be considered a lottery?
Answer: 

Allow anyone to enter the drawing whether or not they sign up for e-sign or have an account.

First published on BankersOnline.com 10/17/11

First published on 10/17/2011

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