Should we/ are we required to provide a line of credit of $5,000 or less to cover overdrafts on one of our director's business checking accounts?

You are under no obligation to provide a ODL to anyone.

The director should be credit worthy for the ODL just as anyone else should be credit worthy.

BTW, a related interest of the insider is not subject to the overdraft limitations. See 215.4(e).

Thanks Dan - in follow-up -- If we offer OD protection on the business account of the director, it would not have to be counted toward the $5,000 line of credit requirment?

215.3(b)(6) Indebtedness of $5,000 or less arising by reason of an interest-bearing overdraft credit plan of the type specified in Sec. 215.4(e) of this part;

Since an overdraft to a related interest is not covered under 215.4(e), it could not be excluded from the definition of an extension of credit.

Would the 215.4(e) exception apply if the overdraft was on our executive officer's son's account, but the executive officer is also an owner on his son's account? Is this a related interest account if the EO is an owner?

If the EO is a joint owner of the account then it his account and subject to all the restrictions.

So just to make sure I understand - the EO is a joint owner but the OD is under $1,000, he was only overdrawn for one day and he was charged the normal OD paid fee. We did not violate Reg O, correct?

Correct.