Enforcing the demonstrable consent requirement isn't necessary for non-consumer accounts. But you do need consent, nonetheless, and a recommend it be either written (paper) or verifiable and attributable electronic permission.
In your business enrollment, include a reference to each of the types of items you can provide electronically, including any notices of dishonor on deposited items, etc.
One other thought: I think it's a good idea to emphasize in the enrollment "dialog" with your business customer the importance of ensuring that estatements be picked up and examined promptly, and that they be picked up by someone who doesn't write checks on the account, if possible. If possible, demonstrate how easy it is for the business to check its account activity daily for questionable transactions.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8