If an individual has a credit card but no other deposit, loan, safe deposit box account, etc are they still subject to a 314a search? My feeling is yes since a credit card could be considered as a loan but I would like confirmation. Thanks.

We search all of our credit customers, including the ones that only have that relationship with us. We do consider it a loan account.

A credit card is a loan and would be included in the 314(a) search.

It is safe just to use your whole client database. There should be a aggregated list on your core system.

But yes, a credit card should be included. It is part of your consumer lending.

When you sign into the 314a system and you get to the "Institutions Menu" you can click "Answers To Your Questions" then "Instructions" and it has everything they require.