We are going to be holding a promotion for a checking account. Part of the promotion is a prize drawing for a $500 Visa Gift Card. I know that in order to offer such a drawing we have to allow anyone to enter and can not require that the checking account be a condition of entering.

Marketing wants to do the following: allow anyone to enter (disclosing it in the official rules) but advertise it in the promotion ad that you have to open an account. I have an issue with that.

To meet management's request would the following statement be okay?

"Open a Star checking account to be automatically entered into a prize drawing for a $500 Visa Gift Card."

The Official rules would then explain that no purchase is necessary and how they can enter without opening an account.

Any thoughts or advice?

"Open a Star checking account to be automatically entered into a prize drawing for a $500 Visa Gift Card" does not "advertise (it) in the promotion ad that you have to open an account".

Presuming that there are no unreasonable challenges to entry, you should be fine.

Al

Check your State's sweepstakes laws. Some states require that you tell them how to enter or obtain the offical rules.