That's a great question and what I'm wondering. We are going through a system upgrade, including new forms. We were asked if we wanted TIS included in our business disclosures which got me thinking (not always a good thing). As I did more research I read several times that TIS is not necessary for business accounts. It's not that we don't want to include it but we were told during a recent audit that our fee descriptions on marketing information, disclosures and statements must all match exactly. It's not a problem for our consumer accounts but for business accounts we don't have the option of modifying the description. It's just a very generic term of Cycle Service Charge. Also, if there is more than one fee charged, the fees are all lumped together on the statements with that description. I questioned our auditors that TIS only applies to consumer accounts and they came back with a potential UDAAP issue on the business side if they don't match.
I'm sure this is way more that you cared to hear about but I was just thinking that by not including a TIS we would eliminate the whole problem.