REG O and ACH Exposure Limits

Reg O Sec 215.3(a)(7)(Extention of Credit) states 'Any other similar transaction as a result of which a person becomes obligated to pay money...to a bank, whether the obligation arises directly or indirectly...or by any means whatsoever.'

Sounds like bank Directors that own businesses that Originate ACH entries should have to include their ACH $ exposures in the amount of total credit exposure allowed. Am I reading this correctly ? Thank you for any insight.

Although there is risk involved when a bank (as ODFI) accepts ACH entries from an Originator, it's not technically considered credit risk.

I think it's a reach to include that risk as "credit" when determining total credit exposure to an insider.

Many banks count ACH in total credit exposure, but not for Reg O purposes. It is a risk, not actual credit owed.

Thank you John and Kathleen B.