1.Purpose
Philanthropic activities and initiatives play a critical role in the support and fulfillment of the University’s teaching, research, and service mission. Approved raffles, contests, drawings, giveaways, and promotions are tools that can be used in fundraising, engagement, and marketing. The University community must utilize this policy to conduct Raffles, Contests, Drawings, and Giveaways/ Promotions (collectively, “Promotional Event” or “Promotional Events”) consistent with legal standards and obligations.
2.Scope
This policy applies to all employees (including faculty, exempt professional, and SHRA staff) and students.
3.Definitions and Roles and Responsibilities
3.1Definitions
3.1.1Associated Entity
An “Associated Entity” is a private, non-profit organization, which supports the mission, goals, and objectives of UNC Greensboro. Activities undertaken by Associated Entities include fundraising, provision of services to students and campus organizations, research support and collaborating with organizations outside the University System to promote and support initiatives and activities that are related to the University’s mission of teaching, research, and service.
3.1.2Contest
A “Contest” is a competition for a prize involving actual skill or criteria for winning that is different from a drawing based on luck.
3.1.3Drawing
A “Drawing” is a game of chance where the prize is awarded based on participation or attendance, such as a door prize. Drawings are different than raffles given that individuals do not purchase chances to be eligible.
3.1.4Giveaway/ Promotion
A “Giveaway/ Promotion,” which may also be referred to as an incentive, prize, or experience, is an item of nominal value provided to specific University affiliated groups or individuals.
3.1.5Net proceeds of a raffle
“Net proceeds of a raffle” means the receipts less the cost of prizes awarded.
3.1.6Personal Property
“Personal property” means non-cash, non-gift card prizes, giveaways, or incentives used for a business purpose.
3.1.7Raffle
“Raffle” means a game in which the prize is won by random drawing of the name or number of one or more persons purchasing chances.
3.1.8Student Organization
“Student Organization” means a student organization that has received official recognition by the University’s Division of Student Affairs.
3.1.9University Unit
“University Unit” means a Center, Department, Institute, Office, School, or other operational segment within a Division of the University. Divisions include any of the following: Academic Affairs, Athletics, Business Affairs, the Chancellor’s Office, Information Technology Services, Research and Engagement, Student Affairs, University Advancement, or University Communications.
3.2Roles and Responsibilities
3.2.1Sponsor
The “Sponsor” is the student group, faculty, staff, or University Unit responsible for hosting the Promotional Event. Sponsors are required to comply with all terms of this policy, including reporting out on taxation.
3.2.2Responsible Administrator
The Vice Chancellor for Advancement has designated the Assistant Vice Chancellor for Advancement Operations as the “Responsible Administrator” for this Policy. The Responsible Administrator is responsible for the approval/ denial of Raffle requests and tracking Raffle Sponsors and the number of Raffles.
4.Policy
4.1Contests, Drawings, and Giveaways/ Promotions
University Units may conduct Contests, Drawings, and Giveaways/ Promotions that comply with the business needs of the Unit. Contests, Drawings, and Giveaways/ Promotions are distinct from Raffles because participants do not purchase chances.
Cash or Gift Cards: Units may provide cash or gift cards as Prizes or Giveaways/Promotions. For student, faculty, and staff winners, all cash gifts, including Spartan Cash and gift cards, must be reported as income. See the financial aid and taxation section below. Examples: University Unit awarding a drawing winner a $25 Barnes and Noble or Amazon gift card. Exception: A gift certificate for specific campus merchandise (valued at less than $100) not redeemable for cash.
Tangible Personal Property: Units may provide tangible Personal Property as Prizes or Giveaways/ Promotions. Units are encouraged to keep the value of the Personal Property prize under $100. Tangible Personal Property prizes exceeding $100 in value must be reported. See the financial aid and taxation section below. Examples: University Unit awarding a drawing winner a UNC Greensboro Sweatshirt or tickets to theater or sporting events (not season tickets).
4.2Raffles
UNC Greensboro may conduct up to five Raffles per year, consistent with North Carolina law. Any Raffle conducted by a University Unit or Student Organization counts against the five-raffle maximum. Fee-generating events, including, but not limited to games, shows, and functions which require a patron purchase a ticket, pay a fee, or donate money to attend for a chance to win a prize will be counted as raffles and subject to this policy. Raffle Sponsors must receive approval from the Responsible Administrator prior to their Raffle. Approval may be garnered by completing the raffle application. Student Organization applicants should see more about their requirements in section 4.2 below. Approval timelines will be set by the Responsible Administrator. Applicants are encouraged to submit their applications at least 30 days prior to their event.
Raffles must comply with the following provisions:
- The maximum cash prize (or fair market value for goods) that may be offered in any one raffle is $125,000.
- The total cash prize (or fair market value for goods) offered in one calendar year may not exceed $250,000.
- Raffles shall not be conducted in conjunction with bingo.
- No less than ninety percent (90%) of the net proceeds of a raffle shall be used by the nonprofit organization for charitable, educational, civic, or other nonprofit purposes.
- None of the net proceeds of the raffle may be used to pay any person to conduct the raffle, or to rent a building where the tickets are received or sold or where the drawing is conducted.
4.3Financial Aid and Taxation
If the pool of eligible participants in a Promotional Event is limited to UNC Greensboro students, the value of the prize must be included as a resource to determine the student’s financial aid eligibility. University Units that plan Promotional Events that limit participants to UNC Greensboro students must include information to notify students that the value of prizes must be reported and may affect the winners’ eligibility for financial aid.
University Units that award cash or gift card prizes to students must report the winner’s name, student identification number, description and value of prize, and date prize awarded to finaid@uncg.edu within one month of the Promotional Event.
University Units that award cash or gift card prizes to employees must report the winner’s name, employee identification number, description and value of prize, and date prize awarded to payroll1@uncg.edu within one month of the Promotional Event. These prizes count as income and will be taxable.
Raffle Winnings may be subject to federal and state taxes if the value of the winnings is $600 or more. The Raffle Sponsor must collect, and report to the Responsible Administrator, the winner’s name, address, and taxpayer identification number to comply with Internal Revenue Service (IRS) reporting requirements. Winnings less than $600 are also considered gambling winnings by the winner; however, UNC Greensboro is not required to report these winnings to the IRS. Failure to obtain this information will subject the winner to a higher withholding tax rate, referred to as the backup withholding rate. If the winnings exceed $5,000, the unit must arrange for tax withholding with the Controller’s Office prior to disbursing any winnings.
4.4Student Organizations
Student Organizations that have separate and distinct statuses may be able to host a Raffle under that organization’s nonprofit or charitable status. Before conducting a Raffle, a Student Organization must receive prior approval from the Vice Chancellor for Student Affairs or their designee. The Vice Chancellor for Student Affairs, or their designee, will determine whether to complete the Raffle application on behalf of the Student Organization or whether the Student Organization must complete the Raffle under their national or state organization.
4.5Associated Entities
Raffles, Contests, Drawings, and Giveaways/Promotions conducted by Associated Entities will not be considered University Raffles or Promotional Events for purposes of this Policy and therefore not subject to its terms.
4.6Research
A University Promotional Event conducted as an incentive to complete academic research activities may be controlled by Office of Research and Engagement policies, not this policy; however, tax and financial aid implications for prizes still apply.
5.Compliance and Enforcement
University Advancement will establish standards, procedures, and protocols in support of this Policy. Individuals in violation of this policy may be subject to disciplinary action in accordance with existing policies and procedures as defined by the employment classification of the individual involved.
5.1Supporting Documents
5.2Related Policies
5.3Resources
5.4Approval Authority
The Chancellor. The policy will be reviewed periodically by University Advancement, in consultation with the Office of Institutional Integrity and General Counsel.
5.5Contacts for Additional Information and Reporting
- Responsible Administrator: Assistant Vice Chancellor for Advancement Operations, 336.334.4039
- Responsible Executive: Vice Chancellor for University Advancement, 336.256.8597