Putting a new twist on investor incentive programs, American Express Financial Advisors is running a sweepstakes that offers an investment portfolio as its top prize.

The Minneapolis-based operation initiated a mass mailing last month targeting some of the 30 million charge card customers of its parent, American Express Co.

The brochure invited people to check out a range of financial services and enter a competition to win a $50,000 customized investment portfolio.

"We were looking for something that would stand out," said Carole Buller, a marketing promotions manager.

Ms. Buller said the grand prize winner-to be drawn July 31-would get two hours with an American Express broker to help structure an investment profile.

The winner would be given the option of taking home $50,000 in cash, said Ms. Buller. Entrants are not required to open an investment account, she added.

The brochure also invites people to explore financial questions for specific needs such as retirement or funding their children's college education.

The promotion is part of the financial advisory unit's bid to expand its relationships with American Express cardholders, Ms. Buller said. Industry observers said banks could learn something from American Express' cross- selling efforts.

American Express has a lot of relationships with people who do not hold mutual fund accounts with the company, said Avi Nachmany, director of research at Strategic Insight, New York. In that respect, the company is similar to a bank, he said.

Ms. Buller said not all 30 million American Express cardholders will get the sweepstakes mailing.

The company targeted geographic areas with the largest concentrations of both card members and financial advisory offices. American Express has 179 financial advisory offices nationwide and owns or manages $195 billion of assets in two million accounts.

"It's the toaster mentality all over again," said Geoffrey H. Bobroff, a mutual fund consultant based in East Greenwich, R.I., commenting on the sweepstakes. But "$50,000 is a very expensive toaster."

But it could an economical promotion. Mr. Nachmany said an ad in The Wall Street Journal would cost more.

Other institutions have offered incentives but not on such a grand scale, Mr. Bobroff said. Free air miles have generally been the most popular carrot offered to investors.

Star Bank in Cincinnati and Charles Schwab & Co., the San Francisco discount brokerage, each offered air mile-related programs in 1996.

Mellon Bank Corp.'s Dreyfus unit has started exploring a venture with AMR Investments to offer mutual funds and other banking services to frequent fliers on American Airlines, a sister company of AMR.

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