We have turned on the disclosure of total fees 230.11 for consumer periodic statements. Are we required to do this on commercial statements as well?

We applied it to all of our accounts. We have business customers who have Bounce privledges as well.

We applied it to all of our accounts. We have business customers who have Bounce privledges as well.

I'm only doing for consumer.

You don't have to do this on commercial accounts.

Section 230.2(a) of Reg. DD defines an account as follows:

(a) Account means a deposit account at a depository institution that is held by or offered to a consumer. It includes time, demand, savings, and negotiable order of withdrawal accounts. For purposes of the advertising requirements in Sec. 230.8 of this part, the term also includes an account at a depository institution that is held by or on behalf of a deposit broker, if any interest in the account is held by or offered to a consumer.

Here's the rule's definition of consumer.

(h) Consumer means a natural person who holds an account primarily for personal, family, or household purposes, or to whom such an account is offered. The term does not include a natural person who holds an account for another in a professional capacity.

You can also look at the corresponding Official Staff Commentary for these items.

I believe it depends on if you already provide any Reg DD information to non consumers now such as service charge breakdowns or apy's.