Answer:
12 CFR 215.3(b)(6)states that the following would not be considered an extension of credit under Reg O: "Indebtedness of $5,000 or less arising by reason of an interest-bearing overdraft credit plan of the type specified in Sec. 215.4(e) of this part." That said, having multiple $5,000 plans would not be an automatic violation of Reg O. However, the amounts of all plans would have to be aggregated and any amounts over the $5,000 exclusion would have to considered as an extension of credit to the EO or Director and meet all other Reg O restrictions.
First published on BankersOnline.com 4/02/07
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