Answer this question: Is it more costly to have a Preferred account than to have a Senior Checking account? By "more costly" I mean higher fees or higher balances to avoid fees.

If the answer is yes, I think you have a problem because that higher deposit account cost can be interpreted as a higher cost of obtaining the credit feature in the ODP.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8