Hello! I have a question about open-ended credit.

If we have a member that is overdrawn in sahre account, or deliguient on a payday loan or Courtesty Repayment Loan, can we rolling the offset amounts onto the back end of another open ended loan they already have? As long as we state this in disclosures...

If you ahve any advice on this or where I might be able to look for guidance, I would appreciate it. Thanks!

This probably is a better question for your attorney than for compliance people. You are talking about the establishment and maintenance of a legal obligation.