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?

I have not heard this strict interpretation either.