Hi all. We are going to be rolling out our ODP program in the next few months. Being that this program does not fall under reg. Z, does anyone know of any implications this may have for reg. O?

For those of you that currently have this type of program in place, do you offer it to employees, officers, directors? If not, why?

Thanks so much and have a great weekend!

We exclude executive officers and directors due to Reg O.

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