We are a small bank and only utilize one bin number for all of our debit cards. I have a customer who has a business checking account (incorporated business). There was recently over a $1,000 in fraud in Florida on the debit card issued to this account. The terms and conditions on the business checking account state that it is not covered. However, the Visa rules says zero liability applies to consumer cards (if I am reading it correctly), and I think they mean the type of VISA card not how the bank has the account set up. Based on the fact that it is a consumer bin issued card, are these charges covered under Reg E even though the account is a business account? Zero liability under VIsa? Thanks.

First, issuing consumer and commercial cards using the same BIN is a violation of VISA Operating Rules.

2.3.4.3 Combining Card Programs on a Single BIN
An Issuer must not combine the following Visa Card programs on a single BIN:
● Credit, debit, and prepaid
● Consumer and commercial
Issuing and acquiring activity may occur on the same BIN.

Second, although Reg E does not apply to business customers, VISA extends Zero Liability protections to small business debit cards so even if you had a small business debit card BIN, Zero Liability would still apply.

https://usa.visa.com/support/small-business/card-benefits.html

If your business card terms and conditions do not include the VISA Zero Liability language, then your disclosures are also in violation of VISA Operating Rules.

Thank you for the help.

I was recently at a compliance seminar and it was stated that if we have the VISA zero liability language in our disclosure we need to remove it. Am I safe to assume this was inaccurate information and it does need to be in our disclosure?