I have been asked by our bank operations group if we can have a contest with prizes to increase the debit card usage for accounts that have a card but with little usage. They are wanting to offer the contest to a group of accounts rather than all deposit accout holders. Can we as a bank limit who can enter a contest?
There is a rule that prohibits a bank from participating in a lottery. This does not appear to be a lottery. The consumer apparently does not have to pay a fee to participate. I am not aware of any specific prohibition on debit cards.
I was just going to post a similar question, I believe the campaign is compliant but am now concerned we may be triggering a bonus.
Here are the details of the campaign:
In order to encourage customers to use their check card more they will deposit $10 into their account at the end of the quarter if they meet the advertised amount of transactions. They plan on doing this a few times through out the year.
In Reg DD it states if a bank give a consumer two or more promotional items that are worth more than $10 combined the promotional items constitute a bonus if given during the same calendar year. Our advertising rep doesn’t feel this falls under the definition of a “bonus” but wanted to get a second opinion, I was wondering if it would fall under “maintaining an account”. Your interpretations are greatly appreciated.