We are a small community bank that is developing a credit card. It is not available to the public yet as we still having testing to do, marketing plans to finish, etc.

Recently, we issued a $10,000 credit card to our Chairman so that we could test that the card gets issued correctly, the billing is accurate, etc. He completed an application and is receiving the same terms that the future cardholders will receive.

Yesterday, we had a bank examiner mention that this may be a Reg O violation! Seems strange that we can't test a new credit card product before issuing it to the public.

Does this sound like a Reg O violation? Any opinions are appreciated!

Sounds like a stretch to me. But if it contains preferential terms and is not available to the general public yet, then it is going to be a judgement call of the regulators. I would fight it and see where the chips fall.