Reg. O is the only potential problem I see and if this is a part of an employee benefit plan, and it is used by more than just insiders, you should be fine. I think I'd also watch the limits each of these "classes" of users have though to ensure it isn't lopsided.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell