In the Appendix to Part 363 ... there is "discussion" surrounding the determination of the final rule ... which includes the following:
The final rule reiterates the requirements of the statute, but does not include specific definitions of "independent person," "large customer," and "banking and financial management expertise". The FDIC expects boards of directors to determine if an outside director meets audit committee requirements. Such a determination will be subject to review by examiners.
My interpretation of Part 363 would allow for limited credit relationships by "outside directors" ... and in practice ... this appears to be in place as well. If you do a "corporate governance" search for public banks ... you will find that their corporate governance policies are available on-line ... and you will see that they allow audit committee members to have a credit relationship. But most non-public banks I observed take a hard-line approach and preclude outside directors from having a credit relationship with the bank.