Bank employees and executive officers have "bank credit cards" that are issued by a different financial institution for the use of bank related expenses only - no personal charges. Payments are made to the card issuing bank.
Does this meet the criteria that is described in Reg O - 215.3(b)(5)(ii) - a bank credit card plan? If so, and credit limits are more than $15,000 (say $18,000), is the credit limit (full $18,000) now considered an extension of credit for that particular insider (Executive Officer)?
(5) Indebtedness of $15,000 or less arising by reason of any general arrangement by which a bank:
(i) Acquires charge or time credit accounts; or
(ii) Makes payments to or on behalf of participants in a bank credit card plan, check credit plan, or similar open-end credit plan, provided: (A) The indebtedness does not involve prior individual clearance or approval by the bank other than for the purposes of determining authority to participate in the arrangement and compliance with any dollar limit under the arrangement; and (B) The indebtedness is incurred under terms that are not more favorable than those offered to the general public