Director owns 5 businesses. He has a personal credit card with the bank for $15,000. Each business also has a $15,000 credit card.

One of the businesses also has a $1,000,000 installment loan that puts him over the prior approval limit.

Are the credit cards exempt from the 14-month approval since each account is $15,000 or less? Or would the credit card balances be aggregated? I'm thinking each individual card would be exempt but want to get another opinion.

The credit card exception would not apply to cards issued to related interests.

Thanks Randy. This is being interpreted from the 2006 letter where it talks about personal purchases?

I am not sure what you mean by your last statement. You stated: Each business also has a $15,000 credit card. Those would not be used for personal purchases and could not be excluded. Otherwise, I am not sure what you mean.

No we're on the same page. I was trying to figure where you pulled your initial answer from as I don't see a distinction in the Reg for a credit card made to the insider vs. a credit card made to the insider's related interest. My response was an assumption that you're interpreting that from the 2006 letter where it does mention personal purchases.