We are not going to promote this - it bascially works like this: update your account information to include: email, current phone number, physcial address, etc. and you'll be included in a drawing for a laptop giveaway. The term "maintenace" is throwing me off....what is considered maintenance - maintaining a balance?

Am I streatching the bonus definition:
(f) Bonus means a premium, gift, award, or other consideration worth more than $10 (whether in the form of cash, credit, merchandise, or any equivalent) given or offered to a consumer during a year in exchange for opening, maintaining, renewing, or increasing an account balance. The term does not include interest, other consideration worth $10 or less given during a year, the waiver or reduction of a fee, or the absorption of expenses.

If you're giving a laptop to everyone, it's a bonus. But the bonus is a chance to win in exchange for having an account with, you, you may have an illegal lottery under banking law or an illegal sweepstakes under your state law.

Look up the definition of lottery, and remember that by limiting this to customers only, who pay you fees and give you deposits, they are paying consideration.

Based on your description, you can't do what you are planning.