Agent Referral Rewards Program

[Barak Schafer]

I am trying to build a referral rewards program for a real estate agent.  I am thinking just offering a gift card.  As far as I can tell, that is legal in North Carolina.  Avoiding discrimination seems to be the big hangup.  My question is how much does it need to be advertised to ensure there is no discrimination going on?  Can we just tell friends and family about the program?  Any advice on keeping this legal would be greatly appreciated.