The reasoning hinges on ACH "risk" lines not being loans. They do not meet the definition of a loan.
Some banks, to avoid LLL risk, will count risks like ACH in the LLL numbers so that if the customer leaves you hanging you have room when the risk becomes a loan.
Good underwriting and management of ACH should avoid that issue, but if the bank pushes up against the LLL, it could happen.
Last edited by MS Kaybee; 09/28/10 07:42 PM.