I need some clarification on the following scenarios and they all have to do with what can be excluded as an extension of credit. I know the individual limit is $100,000, for us, and for other than first mortgage and education.

1) EO has two credit cards and each has a limit of $15,000. An extension of credit excludes credit card indebtedness of $15,000 or less. My question is this: is the $15,000 or less an aggregate amount? Therefore in this example, only one credit card would be exempt and the other must be included under Reg. O limits.

2) EO has one credit card with a limit of $60,000. Given the exemption of credit card indebtedness of $15,000, can we exlude $15,000 of the $60,000 and only count $45,000 towards the limits or because the credit card is over $15,000 to begin with, do we have to count the entire $60,000?

3) EO has two credit cards, one with a limit of $5000 and one with a limit of $8,000. Can we exclude both of them because they are less than the $15,000?

Do these same rules apply to the $5,000 exemption for overdraft credit plans?

Based on my understanding of Reg O:

In scenario #1, you can exclude one of the $15,000 limit cards. The other card would be included in the Reg O limit calculation.

In scenario #2, you cannot exclude any of the $60,000 line. You must count the entire credit line of $60,000 towards the Reg O limit calculation. I believe the Reg states specifically that you cannot exclude part of a line - it's all or nothing.

In scenario #3, you can exclude both cards with lines of $5,000 and $8,000 because the total amount of the lines is less than $15,000.

I'm not familiar with the rules on overdraft lines, as we do not offer that product to any insider or employee, but I believe that the same logic would apply.