If your EFT disclosure is not properly worded to indicate that it applies only to consumer accounts, you could be extending protections to commercial customers that could cost you big bucks. For example, a commercial customer has 24 hours to notify you of an unauthorized electronic transaction. Consumers have significantly more time and coverages based on the timing of the notification and the bank often ends up on the losing end of the equation.
There's no rule that I know of that prohibits providing TISA disclosures to commercial clients, but it's generally easier to utilize other types of forms to accommodate earned income credits and other commercial-specific disclosures. Most automated account opening systems have forms similar to TISA disclosures but titled differently for commercial accounts. You want to clearly disclose to commercial customers how the account works, but you don't have to jump through all the TISA hoops. Make sure the TISA doesn't indicate any type of information that is incorrect (perhaps specific to you consumer-type accounts) to ensure you are protected against allegations of misleading and/or deceptive practices.
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