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be open to customers and non-customers alike—again, to ▸ ▸ A bank would not be allowed to limit how much money
avoid that element of consideration. A bank could impose a customer can withdraw from a savings account sub-
certain requirements for all participants, such as “Must ject to a raffle unless the limit would have been applied
be 18 to enter” or “Must be present to win.” Well-written without a raffle; however, a bank may require that a
rules should take care of the issue of consideration, thus deposit subject to a raffle be in a savings account for a
avoiding lotteries and anti-gambling laws. specific period to be counted as an entry in that raffle;
▸ ▸ A bank would be required to pay interest or dividends
SAVINGS PROMOTIONAL RAFFLES: In 2017, the Texas leg- on a savings account subject to a raffle at a similar
islature passed a bill amending the state Constitution, rate to what would be paid if there was no raffle; and
which was later approved by voters. That change allows ▸ ▸ A bank would be required to maintain records on
banks to “award prizes by lot to promote savings.” The savings promotion raffles.
federal government started allowing such incentives
with the American Savings Promotion Act in 2015. The Fi- ou can tame raffles, lotteries and sweepstakes—
nance Code, Chapter 280: Savings Promotion Raffles, and certainly take advantage of the newly
established the following rules: Y approved savings promotional raffles—to pro-
▸ ▸ Each entry in a raffle would have an equal chance of mote your bank. The trick is to craft any raffle, lottery or
being drawn; sweepstakes carefully with your legal counsel to comply
▸ ▸ A raffle would not be permitted to jeopardize a bank’s with various rules and regulations. H
safe and sound operation;
▸ ▸ A raffle would not be allowed to mislead customers Kelly Goulart—a certified regulatory compliance manager,
or depositors; certified anti‑money laundering specialist and certified
▸ ▸ A bank would not be allowed to require additional internal auditor—is IBAT’s regulatory compliance senior
fees to enter a savings promotion raffle; manager. Contact him at 512/275‑2231 or [email protected].

Exciting things are happening

at Moody Bank!

» We have a new brand look to reflect who we are and where we’re going

» We’re building banking centers of the future with open designs and advanced technology
» We’re expanding in Central Texas beginning with a new banking center in New Braunfels

» With more than $1 billion in assets, we’re the 6th largest community bank
in greater Houston*

» Our growing Wealth Management & Trust department, one of the oldest and
largest in Texas, is responsible for more than $30 billion in assets**

Building relationships
in Texas since 1907

www.moodybank.com
* According to the Houston Business Journal 2017 ranking of Houston-area community banks based on
assets reported to the FDIC.
** Moody Bank Wealth Management & Trust products are not a deposit, not guaranteed by the bank or its
affiliates, not insured by any agency of the U.S. Government, and involve investment risk. A possible loss of
value may occur.

MAY–JUNE 2018 | 11