I have a call in to my regulator, however, would like some responses as to how other bankers interpret this or your experience in exams. Section 215.9 of Reg O requires executive officers to report debt at other banks if it exceeds cerain thresholds. Our officers have asked two things and I'm not sure of the answers. One is, "Is a LLC considered a partnership?" If so, debt at another bank of a LLC would need to be reported. I would think LLC falls within the category of a corporation, but the execs want to make sure - and so do I. Secondly, if an exec officer has, for example, 5 credit cards with lines exceeding thresholds, would these need to be reported? At first, I thought no, but the more I think about it, it is debt at another bank. Thanks for your help!

First, I agree with your interpretation - an LLC is not a partnership, it is a corporation.

As to the second, if the XO has cards that exceed the $15,000 threshold in the aggregate, I think they are all extensions of credit. As such, they are subject to inclusion in the amounts subject to reporting under 215.9.

I would agree as long as the credit cards are from other "banks". Credit cards from brokerage houses not owning or owned by a financial institution would not be counted toward the other credit limit of $100 thousand.