Question:
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?
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