Hosting a Halloween Costume Contest
In this potentially embarrassing Halloween special Compliance Clip, Adam answers this week’s question dressed as none other than…. well, you will have to watch the video to see. (And stick around to the end if you need an explanation of who it is!)
Video Transcript
The following is a transcript of this video.
Hi, welcome to the Joy of Compliance. My name is Adam Witmer. If you're new to us, I wanna extend a personal invitation for you to grab your brush and paint regulation over everything that was once beautiful. If you've been with us before, I wanna thank you for spending your time with us. Now, let's begin.
Our question for today is, “Are we permitted to host a costume contest where customers vote for the best dressed employee on Halloween?” The answer to this, of course, could come from a number of places. It could come from Regulator Lottery Rules. It could come from State Lottery and Sweepstake Rules. It could come from Facebook rules or potentially other considerations. The most important thing that we have to worry about today, of course, are your Regulator Lottery Rules. Specifically, the FDIC says that banks cannot hold a lottery.
A lottery includes a number of things. It includes an arrangement other than a savings promotion raffle, whereby three or more persons advance money or credit to another person in exchange for the possibility or expectation that one or more but not all of the participants will receive by reason to their advances more than the amounts that they have advanced from either a random selection or a game, race or contest. So in our original question, we asked whether or not a costume contest where customers vote on employees and an employee would get a prize, if that's the case, the customer's not getting anything back and that way, that would not be a problem for compliance purposes. Now, if your customer got a prize, that would potentially be a problem and be subject to these rules.
That's all we have for you with this show. If you want to clean your brush, what you can do is just beat the devil out of it. Hopefully, we will come back and we'll paint some happy little trees in our next episode. Thank you for watching the Joy of Compliance with me, Adam Witmer.
Thanks for sticking to the end. If you don't know who I am, I am Bob Ross. This is who I dressed up as for Halloween. Bob Ross was a longtime host of the Joy of Painting on PBS, and he did this out of Muncie, Indiana. I'm from Indiana, so it's a big deal for me. I like Bob Ross. Go ahead and check him out. Thanks for watching the Compliance Cohort in this very unique clip. I hope you enjoyed it and I hope you have a wonderful day.