I'm not seeing anything particularly that covers this question, so I'm looking for more expert thoughts than mine:
We granted a borrower a LOC several years ago from which they could take advances to purchase trucks. These advances would then be immediately termed out through conversion to a commercial loan without benefit on an underwriting or approval (since the line had already been approved.) Availability on the line was reduced by the advance and availability was not returned on conversation to a term loan.

Since the LOC was approved and originated years ago, are these subsequent term outs considered originated loans?

Define this please: We granted a borrower a LOC several years ago

You mean the bank and borrower signed a legal agreement outlining this commitment ahead of time setting forth the terms of the master line of credit and the treatment of the draws that are granted?

Or was this in internal guidance line that was approved without an actual legal agreement/commitment with the borrower?

We have signed Security Agreements, Guarantees, a Line of Credit Agreement all in file.

Then I would say the loan was made long ago.

Thank you!