(A) a random selection;..."
Interpretations in the past have held that the fees a customer pays the bank fits the "advance money to another" requirement and they hope to win more than they pay. This could classify your program as a lottery. For this reason these programs are generally open to the public. That is what gets them away from being a lottery.
I can't say that your program is or isn't. While you might assume there is a bright line test here, this isn't always the case. How conservative are you, what risks would you assume making your own interpretation, and will state laws come into play? You must answer these questions, or simply contact counsel.
------------------
Andy Zavoina
Opinions stated are not necessarily that of my employer.
I had counsel's opinion that a customer's doing business with us, and paying account fees, could loosely be considered their payment, their consideration. That is why I am suggesting you determine the risks you'll accept (based on other opinions expressed here) and your own interpetation.
There were state (TX) specific issues that influenced the opinion our counsel provided. You may or may not have the same issues. But your definitions of consideration may differ from someone else's.
This could be a touchy subject ripe for litigation or a "who really cares" when all is said and done.
------------------
Andy Zavoina
Opinions stated are not necessarily that of my employer.
Obviously, you should check any State laws.
On the other hand, if you offer existing customers the opportunity to participate and all they have to do is answer your questions, I don't believe there would be a problem under our state law. See if your state statute is similarly constructed.