We were audited by a third party and given guidance on language to add under Reg. E in our terms and conditions regarding personal checking accounts used as a business. Basically, we were asked to add something to the effect of "if you have a personal checking account, but are using it for business purposes" (Avon, Amway), etc. "If your account is electronically debited via ACH using a standard entry class code of CCD, you have only two business days to notify the bank if this charge is unauthorized and needs to be returned to the originator. This is due to the fact that a CCD entry is not a personal transaction and does not fall under rules set forth in Regulation E."
I have looked at other bank's disclosures and I haven't found anything that addresses this issue. Are we being asked to do something that we shouldn't by an overzealous auditor?