Would the following director's corporate credit card fall under Reg O as an insider loan assuming the 15,000 exemption does not apply?

The card is to be used for business expenses but could possibly be used for personal charges
The card is “owned” by the individual card holder not the corporation and application for the card is in the individual’s name.
The card obligation is guaranteed by the corporation which ultimately makes it an credit obligation of the corporation.
The corporation directs the bank to withdraw cards if a person leaves employment or retires from the corporation.
The corporation sets card limits based on their willingness to guarantee an individual’s credit card threshold

IMO that statement makes it subject to Reg O. Regardless who guarantees the loan if the insider is the owner of the account they are liable for the account therefore the account is subject to the provisions and restrictions of Reg 0.

Yes. This is subject to Reg O as the individual is personally liable.

"The card obligation is guaranteed by the corporation which ultimately makes it an credit obligation of the corporation. "

I'm a little confused by this statement. How is this different than any of the other credit cards the bank issues? If the cardholder does not pay on any card, the bank ultimately pays the bill via charge-off.

Who holds this debt and who is guaranteeing this debt? Are there multiple entities involved? Is there more too this story?

We'll see what the poster says, but I did not read this as a card issued to the director by virtue of being a director of the bank but by being an employee of a company that has arranged for corporate cards issued by the bank. The cards are issued to individuals, usually for business expenses, and guaranteed by the corporation.

The director as an employee of the corporate customer of the bank receives one of these cards and is personally liable, while the corporation does guaranty.

Well, I guess that was my question. If the bank has to guarantee the card, do they actually hold the credit account? What real value is the guarantee if they do? If the officer doesn't pay, the bank pays one way or another. Whether held as a direct or indirect liability of the bank, it would still be processed against ALLL. If there are multiple entities (affiliates) involved, this may or may not have Reg. W implications.

The employer is guaranteeing the card, not the bank. The director works for another company - that is the company that guarantees his card.

OK - got it now - just a little slow this weekend I guess.

I can sympathize entirely!