Did the bank provide John Doe its standard Reg E disclosures when it opened the account for this sole proprietorship? If so, you may have to honor those disclosures, unless the disclosures included a prominent disclaimer like "The following disclosures apply only to accounts opened by individuals primarily for personal, family or household purposes."
If you instead have a separate Debit Card Agreement for business accounts, and that's what Mr. Doe received, then the answer to your question should be found there.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8