Under Reg O are there any ramifications on a credit card of an Insider that is over its limit? Assuming we allow other credit card holders to go over the limit, are there any restrictions in Reg O against it? It seems like an "overdraft" but it does not fit the OD definition in Reg O because it is not in excess of funds in a deposit account. It just seems wrong, but I can't find anything in the regulation. We do charge normal interest to the Insider as we would any other account.

Any amount above the limit would be additional credit extended and would need to follow the appropriate approval process for the insider.

Thank you Dan. Much appreciated.