Well, we are assuming that the purpose of the loan is business or commercial. If an individual wants a loan for a personal, family or household purpose, it can't be on a "commercial note" because it's not set up to provide TILA disclosures.
Only of the loan is large enough (over $58,300 currently) and isn't a private education loan or secured by real estate or a dwelling can you ignore Reg Z when the loan is for a consumer purpose.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8