If the EEPROM on a card is directly connected to the card’s contacts, then the EEPROM can be programmed independently from the processor. When this is the case, those direct connections are called the direct programming lines. You will find DPL on SMD or HMD cards only. Goldwater’s don’t utilize DPL and will therefore always need a loader file in the processor chip in order to program the EEPROM on the card.