We are thinking of running a promotion where our customers would be entered into a drawing each time they use their debit card to make a purchase. We would also allow mail in entries. My question is if using debit card purchases as an entry is "consideration". My initial guess is no since we will allow mail in entries and we are not asking our customers to purchase anything from us (and our debit cards are free). Thoughts?

You cannot require a debit card purchase to qualify so the mail in entries are good. You also must make the drawing open to customers and non-customers.

But can we "allow" a debit purchase to equal 1 entry since we have the mail in option as well? We would allow the mail in entries to be as many as the person wanted to send, as long as it was 1 entry per envelope. And yes, it would be open to everyone, not just our customers.

What about the cost of a stamp? Do you think that could be construed as being something of value that needs to be advanced for "consideration"? (Just trying to think of all the angles!)