Although BSA requires a purpose for loans over $10,000 (not secured by real estate) how do credit card accounts by-pass this requirement?

I never see a purpose question on a credit card application.

It's the nature of the beast...they are generally either miscellaneus business purpose or consumer purpose. There's no way to really catagorize open-end credit...generally speaking.

I agree that its almost impossible for the consumer to know the purpose in advance. But examiners generally don't generally accept logical answers, so is the BSA requirement just ignored by them?

for that type of credit...yes. Other processes would take priority such as "know your customer/CIP" and typical transactions. They would look to you to have tools in place to alert you if there were "unusual" transactions occuring, IMHO.

For a credit card LINE, there is no single purpose. The available balance may be used to by fast food to a car. The Purpose can't be known at issue unless the card is issued for a particular purpose and isn't a revolving line.

Frankly, the requirement was written well before it was common for consumers to have lines of credit -- home equity, credit card, or otherwise -- over $10,000. If a given line is applied for to make home improvements (at least to start with), the application should reflect that. Otherwise, it shouldn't be unreasonable to see "personal line of credit" or something equally non-specific.

Thanks all for your help. It sure would have been nice if there was an Administrative Ruling on this subject.

That's why you just gotta LOVE compliance!

Well-said.