Reg D NOW eligibility

I have a business that has supplied documentation listing them as a "Special Purpose Government Entity (SPGE)." This business currently has a NOW account, but is not a government entity itself. The question of eligibility has come up during a Reg D review. I feel like this documentation qualifies for a NOW, but wanted some input. Thoughts, please?

If you read carefully section 204.130 of Regulation D, you won't see "special purpose government entity" in any of the entries. I don't think you've got a qualified depositor.

Sooner or later, perhaps once rates start to creep upward a bit more, banks are going to tire of this discussion of who is NOW-eligible. Once they convert all their NOW accounts (or just the non-personal NOW accounts) to interest-paying DDAs, they can consign the discussion to history.

Thank you for your input John!