When determining the $100,000 limit on Executive Officer loans, it is the total amount of the line of credit that counts, not just the outstanding balance, correct? If an EO has a $15,000 unsecured line and a $100,000 HELOC even though he hasn't drawn over $100,000 we still have a violation, right?

Yes you do - limits are calculated on the commitment amount, not just the amount outstanding.

You may not have a violation. 215.3(b)(5) exempts open-end credit plans of $15,000 or less. They are not "extensions of credit." And the $100K HELOC is authorized under the "other purpose" in 215.5(c)(4), provided that your bank's capital is at a level that $100K is your limit.

Thank you so much for that - I should have checked the definition myself. I do not like making mistakes on something as simple as reading a definition.

Be careful, though - that $15,000 exemption applies to credit card or similar arrangements. If you are talking about overdraft lines, the limit exemption is just $5,000.