[Kristin]

If the bank were to sponsor the cost of printing raffle tickets for a school’s auction – not sponsor any items or donate anything to the raffle, just pay for the cost of printing the actual tickets, would this be considered participation in a lottery? We are being asked to cover the cost of printing the tickets in exchange for our logo to be printed on the tickets and aren’t sure if this is prohibited or would just be considered advertising?

[rcooper]

At first glance this may seem fine, because you aren’t selling the tickets nor are you permitting them to be sold or advertised on bank property. But the regulations state:

Banks may not:
(1) deal in lottery tickets;
(2) deal in bets used as a means or substitute for participation in a lottery;
(3) announce, advertise, or publicize the existence of any lottery; [1]
(4) announce, advertise, or publicize the existence or identity of any participant or winner, as such, in a lottery.
Deal is defined as:
(1) The term “deal in” includes making, taking, buying, selling, redeeming, or collecting.

It could be deemed that you are dealing in tickets by paying to have them made. In addition, having your name stamped on the ticket could be seen as paying for advertising via ticket sales. I suggest finding another way to help with the fundraiser. Here are a couple of interpretative letters that might give you insight on what examiners consider permissible (e.g. a general donation to the event or donating an item):
https://www.occ.gov/static/interpretations-and-precedents/jan01/int900.pdf
See page 2: https://www.occ.gov/static/interpretations-and-precedents/jan02/int923.pdf
FDIC Regulation: https://www.fdic.gov/regulations/laws/rules/1000-2200.html
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