Yes, absolutely. You want to make this site look as legit as possible, and update it frequently (all part of appearing legit). Make USEFUL status updates on a regular basis and make sure you have a high interaction rate with the fans of your page(s).
If you are using FBML code as you mentioned,
definitely do not add any force invite codes, or any invite codes period. Also, to make sure you keep your fan pages alive, I strongly advise not posting any CPA offers anywhere on your pages; leave the CPA offers for your legit-looking website.
You can also get a custom landing page designed that targets the niche of your fan page and signup with AWeber or GetResponse and collect double opt-in leads that you can legally blast with CPA offers. However, I am not so sure how safe it would be to post a link to your landing page(s) directly on your fan page. You might want to have a link to your landing page(s) on your website, or have the form on your website where visitors can submit their E-mail for double opt-in confirmation and just skip the landing page.
This is all I can think of for now, I am in a very friendly mood right tonight.
If I think of anything else I'll post another reply. If you have any questions, you can feel free to PM me. Also, kudos to you for figuring out how to make multiple fan pages go viral without having to use forced invites, invites in general, and without having to even send out any invites yourself. Nice job man!
NOTE: I am not trying to be rude, but I am only offering the OP to PM me if he has any questions. I would be open to PMs from anyone, but I simply do not have that type of time and he is the OP after all.
OP, if this helped you (or anyone else), I would greatly appreciate it if you would hit the "Thanks" button. Heck, even a +Rep would be nice, but no one has to do either of these things. Just a friendly request.