It is the same debit card that is issued to consumers. And, we've been issuing them to any entity that requests it.

I feel we shouldn't give the commercial customer a consumer disclosure. But CO, says sice we issue a "consumer" product to commercial account we must give them the REG E consumer disclosure. Any thoughts on how to dispute this?

What about the zero-liability thing? I understand that zero-liability for VISA coveres their buisness cards, too, but can we contract that away in our account agreement or since the cards bear the VISA logo are we stuck with zero liability?

Reg GG? In what respect? All new commercial account customers are being advised on the new regulation and we are actually hilighting that particular section on the account terms and conditions, and getting all of them to certify that they are not engaging in an Internet Gambling Business within the meaning of Federal Reserve Regulation GG.

If they are engaging in Internet Gambling Business, then the process is much, much more involved. (Management will determine if we will actually open the account or not.)

What are you guys doing?