We have overdraft protection products for our business accounts. I am second guessing the fact they should not be reported as small business loan originations. Am I right? or do they need to be reported? If so where does it state that? I have looked at the CALL report instructions under commercial and Industrial loans and that section does not specifically include or exclude them. I also can't find it in the CRA GIR. Help!!!!1

I was just having this same conversation with myself this morning. I'm leaning toward reporting them as they really are a "line of credit". The fact that they only get accessed when there is a cash flow issue should not really matter.

Thoughts?

Is this a formal OD LOC? If so, I would tend to report it.