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#314845 - 02/10/05 05:33 PM Reg O- Employee Benefit Program
Last Mango Offline
Gold Star
Joined: Mar 2001
Posts: 293
Too Far From the Beach
Regarding Reg. O, 215.4(a)(2), I have been told that if we want to allow insiders to benefit from discount loan rates as part of an employee benefit program, the employee program must allow the rate reduction for part-time employees and employees that are still in their probationary period. I‘ve searched the FRB’s website, several manuals, and this website and could not find any mention of this stringent interpretation. IMHO, the term “widely available” does not mean “all employees”. Any thoughts?
If you keep living straight from the heart, you will know when to stop and to start.

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Lending Compliance
#314846 - 02/10/05 06:00 PM Re: Reg O- Employee Benefit Program
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,478
Bloomington, IN
I have not heard this strict interpretation either.
The opinions expressed are mine and they are not to be taken as legal advice.

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