I thought credit cards in the amount of $15,000 or less were not considered extensions of credit under REG O? Did something change?

I want to clarify my post I am referencing 12 CFR 215.39(b)(5) An extension of credit does not include an indebtedness of $15,000 or less under a bank credit card plan.
The credit cards I am asking about are personal credit cards that they applied for, were approved and pay on their own. The Insiders that have $15,000 or less is not included in their debt calculations for REG O lending requirements. Is this correct?

OOps meant 12 CFR 215.3 (b)(5)

If they use the card for personal purposes - you cannot exclude them. See this FRB Legal Interpretation:

http://www.federalreserve.gov/boarddocs/legalint/federalreserveact/2006/20060522/20060522.pdf

It is a personal card - not a bank corporate card. The personal cards cannot be excluded? I take the outstanding personal Charges and aggregate it with the other indebtedness and if it is more than $15,000 I cannot exclude?

A reference in the fedreal reserve letter Says Section 215.3 (b)(5) of regulation O excludes from the definition of extension of credit indebtedness of up to $15,000 incurred by an insider with a bank under an ordinary credit card.

That is what the cards are I am talking about.