Ilistened in on the FDIC Reg DD conference call and I thought I understood them to say that if new accounts personnel discussed how our ODP (privilege) program worked at the time of new account opening, that would be considered promoting it, thus prompting the other big 4 disclosures. Is that correct?

If so, what is the exemption in 12 CFR 230(b)(iv) - "an in-person discussion" for?
I would appreciate any clarification.

About 2/3 of the way through this thread your question was raised. The section you cite makes it abundantly clear that "in person" discussions are not a trigger.

As for what may have been said in the phone call, I haven't a clue. Contact the presenter.

Thank you. That's what I thought. I did ask and have not yet received a response.