[OMS_MANAGERS] FW: Question about raffles for Main Street orgs

Tue Aug 28 17:57:02 PDT 2018

You can also get around gaming rules if you structure it as a
sweepstakes by adding a no purchase necessary option. I'm surprised that
you were allowed to do the receipt raffle in that way because the purchase
of merchandise at a business in exchange for the chance to win something is
technically "consideration" to a for-profit business. Consideration
constitutes gaming and for-profit businesses are not allowed to engage in
gaming outside of hosting lottery machines or selling lottery tickets.

For our Snowflake Raffle, entries are given with purchase at participating
business. We also accept mail-in entries to get away from the issues
surrounding gaming, which based on my understanding when we first launched
the event four years ago was not allowed.

Don't want to supply a wrinkle, just a perspective based on our legal
counsel at the time.

On Tue, Aug 28, 2018 at 5:46 PM, Lise Grato <director at albanydowntown.com>
wrote:

> Don’t think I chimed in on this, my apologies if I already did.
>
>
>
> We ran into the RAFFLE question this summer as well, but ours was under
> $10K and OK without a license.
>
>
>
> For our Movies at Monteith event we wanted to encourage attendees to shop
> or dine downtown before coming to the park. We wanted individuals to bring
> a Downtown receipt to enter a drawing (didn’t matter how much they spent or
> when).
>
>
>
> I contacted DOJ and was told the type of little drawing Albany Downtown
> Association wanted to do was a raffle. But we didn’t need a license as it
> was under the $10,000/year threshold. We were required to place a value on
> the tickets, to track ticket “sales”. We valued the tickets at $1 which
> made sense for a $40 prize. See email attached.
>
>
>
> For the prize I wanted them to shop around Downtown again. I asked
> businesses to donate a $10 gift card. I  bundled a mix of 4 cards for the
> $40 prize. I like having the winner go to 4 places, and it’s a small ask
> for our business owners. I use this same strategy for our Business Mixer
> prizes as well. Some businesses want to give more depending on the event,
> so I ask for multiple cards at $10 each and create multiple theme prize
> packages (Shopping Spree, Dine and Unwind, etc.)
>
>
>
> I plan to do a number of receipt drawings this year.
>
>
>
> Hope this helps.
>
>
>
> Thank you,
>
>
>
> *Lise Grato*
>
> Executive Director
>
> Albany Downtown Association
>
> 126 SW Ferry Street
>
> Albany, OR 97321
>
>
>
> Email: director at albanydowntown.com
>
> Phone: (541) 928-2469
>
> Cell: (541) 905-2908
>
>
>
>
>
> *From:* OMS_MANAGERS [mailto:oms_managers-bounces@
> listsmart.osl.state.or.us] *On Behalf Of *Jonathan Stone
> *Sent:* Tuesday, June 26, 2018 10:55 AM
> *To:* Oregon Main Street program managers <oms_managers at listsmart.osl.
> state.or.us>
> *Subject:* Re: [OMS_MANAGERS] FW: Question about raffles for Main Street
> orgs
>
>
>
> We recently did the research. You need to apply for a license from the
> DOJ. https://www.doj.state.or.us/charitable-activities/
> charitable-gaming/charitable-gaming-license-applications-and-reports/ The
> rules are very strict. The application process helps you understand the
> rules.
>
>
>
> On Tue, Jun 26, 2018 at 10:53 AM, STUART Sheri * OPRD <
> Sheri.Stuart at oregon.gov> wrote:
>
> *This message is being distributed over the OMS listserv. All responses
> will also go over the listserv.*
>
>
>
> The Dalles Main Street is looking for info re: raffles – see below. Any
> advice for Luise?
>
>
>
> Thanks, Sheri
>
> *From:* Luise Langheinrich [mailto:lllcubed17 at gmail.com]
>
>
>
> Hi Sheri,
>
>
>
> Hope your summer is going well.  I have a question about running a
> raffle.  We did one in February and raised $6k.  We would like to do one in
> September and hopefully bring in alot more.  The prize is an $8k trip for 2
> on a cruise.
>
>
>
> It looks like we have to get a license from Oregon Charitable org.  But do
> you have any insights or experiences so we can avoid any pitfalls?
>
>
>
> Any thoughts are much appreciated.  Thanks.
>
>
>
> Luise Langheinrich
>
> 541-296-4470
>
>
> _______________________________________________
> OMS_MANAGERS mailing list
> OMS_MANAGERS at listsmart.osl.state.or.us
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> Hosted by the State Library of Oregon. The Library is not responsible for
> content.
>
> Questions related to message content should be directed to the sender of
> the message, by phone or email.
> Technical questions? Call 503-378-8800.
>
>
>
>
>
> --
>
> Jonathan Stone
>
> *Executive Director*
>
>
>
> Downtown Oregon City Association
>
> 814 Main Street
>
> Oregon City, OR 97045
>
>
>
> jon at downtownoregoncity.org
>
> Office (503) 802-1640
>
> Direct (503) 802-1639
>
>
>
> fb.com/downtownoc <http://www.fb.com/downtownoc>
>
> downtownoregoncity.org <http://www.downtownoregoncity.org>
>
>
>
> Subscribe to our email list for:
>
> Property and Business Owners and Volunteers <http://eepurl.com/HBw0D>
>
> Downtown Events and Promotions <http://eepurl.com/HvgAX>
>
>
> ---------- Forwarded message ----------
> From: Stafford Susan <Susan.Stafford at doj.state.or.us>
> To: <director at albanydowntown.com>
> Cc:
> Bcc:
> Date: Wed, 1 Aug 2018 12:26:25 -0700
> Subject: RE: Bring a receipt to enter the drawing?
>
> Good Afternoon Lise,
>
>
>
> Thank you for your email regarding the drawing your organization is
> considering.  Since the participants would have to make a purchase in order
> to receive a ticket to be entered into the drawing this would be considered
> a raffle.  You would need to determine a value for the tickets, so as to
> track your ticket sales.  This will help as eligible organizations (tax
> exempt nonprofits) are allowed to receive up to $10,000 in ticket sales
> without obtaining a license from our office.
>
>
>
> A drawing is considered to be a raffle if someone has to pay something in
> order to have their ticket drawn for a prize.
>
>
>
> Please let me know if you have additional questions.
>
>
>
> Regards,
>
>
>
> *Suzi Stafford*
>
> Gaming Registrar | Charitable Activities | Oregon Department of Justice
>
> 100 SW Market St | Portland, OR 97201
>
> Direct Ph: 971.673.1975  | Office ph: 971.673.1880 | Fax: 971.673.1882
>
> susan.stafford at doj.state.or.us   or  charitable.activities at doj.state.or.us
>
>
>
> *From:* Lise Grato [mailto:director at albanydowntown.com
> <director at albanydowntown.com>]
> *Sent:* Tuesday, July 31, 2018 10:33 PM
> *To:* Charitable EMail
> *Subject:* Bring a receipt to enter the drawing?
>
>
>
> *Hi,*
>
>
>
> I’m trying to find out what the rules are for holding a drawing.
>
>
>
> We are a accredited performing Main Street Program and a 501(c) 6
> non-profit membership organization.
>
>
>
> In the summer we host Movies at Monteith, a free movies in the park family
> event. We are looking for a way to encourage attendees to shop or dine in
> Downtown Albany not just attend our movies with our exploring Downtown. To
> do this, our Promotions Committee wants to hold a drawing for a prize
> valued at $15-$25 (movie DVDs) at the events. Attendees would bring a
> receipt from any local Downtown business to enter the drawing.
>
>
>
> This is the tentative language:
>
> “For an added tie-in to Downtown merchants, attendees are invited to
> bring receipts from Downtown businesses or restaurants to enter a drawing
> for a DVD of that night’s movie.”
>
>
>
> If this is an acceptable practice, what is the limit to the number
> drawings we can hold in a year? Or the total value of the prizes?
>
>
>
> If this is not an acceptable practice, is there a way to provide a second
> way to enter to make it legal?
>
>
>
> Thank you,
>
>
>
> *Lise Grato*
>
> Executive Director
>
> Albany Downtown Association
>
> 126 SW Ferry Street
>
> Albany, OR 97321
>
>
>
> Email: director at albanydowntown.com
>
> Phone: (541) 928-2469
>
> Cell: (541) 905-2908
>
>
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>
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> Hosted by the State Library of Oregon. The Library is not responsible for
> content.
>
> Questions related to message content should be directed to the sender of
> the message, by phone or email.
> Technical questions? Call 503-378-8800.
>

-- 
Jonathan Stone
*Executive Director*

Downtown Oregon City Association
814 Main Street
Oregon City, OR 97045

jon at downtownoregoncity.org
Office (503) 802-1640
Direct (503) 802-1639

fb.com/downtownoc <http://www.fb.com/downtownoc>
downtownoregoncity.org <http://www.downtownoregoncity.org>

Subscribe to our email list for:
Property and Business Owners and Volunteers <http://eepurl.com/HBw0D>
Downtown Events and Promotions <http://eepurl.com/HvgAX>
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