Spin the Prize Wheel

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Question:

At a grand opening or moving project, we would like to use a prize wheel. The prize wheel would only have items that range in value from $1.00 to $25.00. The $25 items obviously being the single panel on the wheel. If anyone who spins the wheel is guaranteed some specialty object or prize, can we use it at an event? In other words, there would be no “Lose Turn” or “Bankrupt” as seen on TV. Prize wheel gifts will be changed on a regular basis. And, in order to be able to spin the wheel you have to bring in the direct mail piece. No account existing or new account is necessary in order to participate. Is this a problem?

Answer:

As always with this sort of question, you have to verify any state law requirements.

You limit the "players" to those with the marketing mailer. Assuming it is not reproducible and if you collect these when the person spins, you will have eliminated the need for IRS reporting because your threshold will be minimal.

The only concern would be who the mailer goes to and do you open yourself to criticism. While there are no "fair deposit" laws comparable to fair lending requirements, if the branch is also making loans you should verify that the demographics of the area where the mailer is going will not appear to be selected on any prohibited basis.

First published on BankersOnline.com 10/26/09