Monthly Drawing for $25 Gift Card-DC Promotion

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Question:

We want to promote debit card usage and management wants to have a monthly drawing for a $25 gift card. I think that this is not permitted since it would not allow non-customers to enter and bank customers with debit cards are the only ones who can win - am I correct? We have seen other banks do this in our area, so management thinks it is just fine.

Answer:

Have you gotten a copy of the other bank's official entry rules?

What you describe is a lottery since the only way to enter the drawing is using the debit card which would be a thing of consideration. You have to devise a way for anyone to be able to enter the drawing so there is no consideration given for the entry.