If you read carefully section 204.130 of Regulation D, you won't see "special purpose government entity" in any of the entries. I don't think you've got a qualified depositor.
Sooner or later, perhaps once rates start to creep upward a bit more, banks are going to tire of this discussion of who is NOW-eligible. Once they convert all their NOW accounts (or just the non-personal NOW accounts) to interest-paying DDAs, they can consign the discussion to history.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8