No, we believe such a display would violate federal law. The Federal Deposit Insurance Act prohibits the use of any part of banking offices to “announce, advertise, or publicize the existence of any lottery.”
This raffle appears to qualify as a “lottery” in which participants advance money in exchange for a possibility to be randomly selected to receive more than the amount they advanced. Consequently, we do not recommend advertising the raffle by displaying the quilt and a sign encouraging participation in the raffle.
For resources related to our guidance, please see:
- Federal Deposit Insurance Act, 12 USC 1829a(a) (“A State nonmember insured bank 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
- Federal Deposit Insurance Act, 12 USC 1829a(b) (“A State nonmember insured bank may not permit (1) the use of any part of any of its banking offices by any person for any purpose forbidden to the bank under subsection (a) . . . .”)
- Federal Deposit Insurance Act, 12 USC 1829a (Prohibiting state nonmember banks from involvement with a “lottery,” defined as “any arrangement, other than a savings promotion raffle, 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) a random selection; (B) a game, race, or contest; or (C) 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.”)
- Federal Reserve Act, 12 USC 339 (Lottery prohibition for state member banks.)
- National Bank Act, 12 USC 25a (Lottery prohibition for national banks.)