Section 20(a) of the Federal Deposit Insurance Act prohibits bank participation in a lottery. The definition of lottery involves people paying money for the possibility of receiving a larger amount of money. For more information: https://www.fdic.gov/regulations/laws/rules/1000-2200.html
It is not clear if you program constitutes a lottery or not. Even if the program is permissible under federal law have your counsel check state law.
I am unaware of any disclosures related to this type of activity.