In addition, the federal banking regulators, including the Comptroller, have always treated a bank's purchase of commercial paper as a loan: it must be treated as such in federally required bank reports, and the Comptroller views the statutory limits on loans to individual borrowers, 12 U.S.C. 84, as distinct from ?? 16's limits on holding investment securities of a single issuer, 12 CFR ?? 7.1180