Can overtime payments be deferred till a later date?

Q: “Our type of industry is very seasonal; during our peak times employees often will work overtime, while during our off-season they do not work many hours. Can our employees choose to bank overtime hours and get paid for them during the off-season time when they work less than 40 hours in a given week? I understand that it is illegal to use comp time for private employers; however we are not giving time off, we are just paying their overtime hours at a later time.” – Cecilia, California