proprietorships, trusts or other entities seeking to qualify as ECPs under CEA ?? 1a(18)(A)(v)(I), under which such entities qualify for ECP status if they have more than $10 million in ???total assets.??? The No-Action Letter states that if a lender has committed to fund a loan in an amount that, when counted as an asset, would permit the borrower to claim in excess of $10 million in total assets