Not stated in the original question is whether this customer is an insider subject to Reg. O. I assume he or she is. If that is the case, an overdraft is an extension of credit, and it would be included in determining whether the total credit of the insider requires prior board approval, has hit a ceiling, or any of a few other Reg. O challenges.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8