I'm not a Reg. O expert so if I'm wrong hopefully someone will correct me. My take on 215.(b)(6) is that any "overdrafts/indebtedness" incurred by virtue of a ODPA of $5,000 or less would not be considered an extension of credit as an overdraft would be if paid without such a plan.
Again, if this is a wrong assumption I'm sure someone will correct me.
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The opinions expressed are mine and they are not to be taken as legal advice.