I've been told that some auditors have made statements that a bank should not post an Overdraft LOC account within the online banking suite available for the customer to view. I was not aware of any prohibition about showing such Lines of Credit within online banking. The only thing I came across that could potentially seem to restrict such a thing is the above section of Reg. DD. However, this part seems more to deal with the prohibition of showing available overdraft capability within the amount shown as the balance of a connected deposit account. Is my analysis correct?

I've been told that some auditors have made statements

Told by whom and what auditors?

It was mentioned in a group I participate in. I had never heard of such a thing before. I thought they would just be like any other LOC as far as online banking.

Well, either group is a little "off" or the auditors were.

So, I am taking that it makes no sense to you either. Am I correct with the TISA analysis? This is a prohibition against showing Overdraft availability within the deposit statement balance?

I have no idea. If all you are saying is that the borrower can see the LOC on their on-line banking account summary and it allows them to drill down into the account transactions, give them current balance, next payment due date, etc., I would have no idea what they were talking about.

That was my take as well, thank you for bouncing it back and forth.