Does the ECOA 30-day clock apply to other types of exposure such as Derivative Hedging? (for example: Interest Rate Hedging LOCs, AKA SWAPs).

What about soft exposure, such as ACH LOCs?

Are they credit as defined by Regulation B?

Good question. Are they?

I'm going to say NO. Per Reg B: "Credit means the right granted by a creditor to an applicant to defer payment of a debt, incur debt and defer its payment, or purchase property or services and defer payment therefor."

For hedging instruments and ACH LOCs, there is no actual payment being deferred.

However, commitments to support Letters of Credit... There is essentially no deferred payment unless the LC is called. But to me, it would still be considered credit (or "contingent" credit).

Any guidance or opinions are appreciated.

Hard to say - I know nothing about Derivative Hedging. ACH are usually internal guidance lines and are not actual credit. But we would have to now exactly what you are talking about.

It really comes down to - is someone signing an actual promissory note.

Nope. No promissory note for a swap or ACH.