I would like clarification about state member banks and the reports their executive officers must file - Section 215.9 of reg O says when an EO becomes indebted to other banks in an aggregate amount greater than what we can lend to them, they must file a report within 10 days... My question is this, if our EO has credit cards with other institutions that total more than $100,000 then they have to report within 10 days of going over $100,000 the details as specified in 215.9, right? Or since EO's are allowed $15,000 in "credit card type" debt that is excluded from the definition of extention of credit (215.3(5)), then is the limit for their 10 day report more than $15,000 or the general purpose $100,000 limit?

bump

I would not leave this determination up to the executive officers and most banks require that they report all extensions of credit.