You would hope that an examiner would not get too picky, but, technically, based on a FAQ from 2004, I'd have to agree that at the time of the loan the borrower was not a customer:
2. Does the exclusion from the definition of “customer” in 31 C.F.R. § 103.121(a)(3)(ii)(C)
for a person with an existing account extend to a person who has had an account with the
bank in the last twelve months but who no longer has an account?
No, this provision only excludes from the definition of “customer” a person that at the time a
new account is opened currently “has an existing account with the bank,” and only if the bank
has a reasonable belief that it knows the true identity of the person. Therefore, for example,
when a person has a deposit account and subsequently obtains a loan, the person has an existing
account with the bank. Conversely, a person would not be deemed to have an existing account at
the bank if the person had a loan, paid it off, and twelve months later obtains a new loan.
In addition the FAQ states that:
Therefore, when the account is a loan, the account is opened when the bank enters into an enforceable agreement to provide a loan to the customer.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius