you need to look at each section of the FACT Act - some apply to only consumers and some are not clear but hopefully will be once the regs are completed. §151(a), for example, regarding turning over ID theft information to victims specifies that businesses are not covered. The FCRA is basically a consumer law, but as we have seen in the past, some portions do apply to the personal information of signers on commercial accounts. I'm just looking at it section by section as the regs are unveiled.
Being kind is more important than being important.