Customer's deposit accounts are closed but he has an open loan. He brings in a check to reopen his deposit account. For Reg CC purposes, can the new account reason be used even though he has a loan? I could not find that the open accounts had to be deposit accounts.

How long has the accounts been closed? Check out the commentary to Reg. CC

VII. Section 229.13 Exceptions - B. 229.13(a) New Accounts

Reg. CC only applies to Deposit account so in my opinion it would not matter if the customer has an open loan.

The accounts have been closed for 2 years. Thanks for the info.

It doesn't matter if the customer has other "non-transaction accounts" open (savings, certificate of deposit, loan) - it would be considered a new account if the customer has no open transaction accounts (checking, NOW).