Is there anything that says the notification requirements of 1002.9(c) regarding incomplete applications do not apply to large businesses (revenues >$1MM) or trade credit?

I stumbled across something interesting while researching this topic. If you look at the exam procedures for both the OCC and the FDIC in the notifications section, the questions regarding written NOI's are specifically directed toward "noncommercial applicants". Why would they only look at consumer transactions if the regulation applies to all credit? Is it risk-based testing, or am I missing something while reading through the Reg.?


OCC's Fair Lending Handbook - page 143 - question 17

FDIC Consumer Compliance Exam Manual - page V-7.14 - question 18