The Uniform Commercial Code 4A is not a law that is biased towards consumers vs. commercial customers like federal regulations or even other UCC laws. Therefore, it is applicable to both. We do not differentiate in our Terms & Conditions who it is applicable to, we just insert the required text.
If you need further guideance, go to the NACHA rules book and check out Appendix 8.2 & 8.3 UCC4A Compliance for the audit requirements, OR3 §2.1.7 - Notice by ODFI, OR3 §2.1.8 - Notice by RDFI, and OG 16 - SAMPLE AGREEMENT ODFI-ORIGINATION (CORPORATE) AGREEMENT (CREDIT ENTRIES), (this gives the bank a sample agreement incorporating much of the UCC4A security requirements.)