Re: Marketing Promotion


Federal law generally provides that a bank may not announce, advertise, or publicize the existence of any lottery; or announce, advertise, or publicize the existence or identity of any participant or winner in a lottery. The term “lottery” includes any arrangement whereby three or more persons (the “participants”) advance money or credit to another in exchange for the possibility or expectation that one or more but not all of the participants (the “winners”) will receive by reason of their advances more than the amounts they have advanced, the identity of the winners being determined by any means which includes:
> a random selection;
> a game, race, or contest; or
> any record or tabulation of the result of one or more events in which any participant has no interest except for its bearing upon the possibility that he may become a winner.

Since the participants in your contest do not have to advance funds it does not appear to fit the definition of a “lottery.” You should check Montana law. I also suggest running this by your friendly local examiner to may sure they are comfortable with the concept.