Answer:
If the promotion qualifies as a lottery, you cannot legally promote it or have anything else to do with it. However, if there are alternative ways for non-applicants or non-approved applicants to enter the drawing without opening a credit card account, there is a good chance that you're dealing with a sweepstakes instead of a lottery. In that case, your state law will tell you whether you're OK to promote it.
First published on BankersOnline.com 9/29/08