Answer:
This is purely an employee benefit issue and you should be working with an employment attorney to craft your program.
Employee Assistance Program (Reg O)
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Question:
The bank is wanting to implement an "Employee Assistance Program". The purpose is to assist employees when they fall on a personal hardship. The employees can make contributions via payroll deduction, one time contributions or not at all. The employee doesn't have to participate in the program to receive any benefit of it. I'm looking for any information or feedback you might have regarding an employee assistance program. I can see that there could be many challenges with implementation and maintaining such a program. Specifically, what regulatory or compliance pitfalls do you see?
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