We are considering allowing our commercial accountholders to have ATM/debit cards. If they lose the card or have unauthorized transactions hit their account, Reg E does not protect them (if I am correct). So does that mean commercial accountholders are fully accountable and responsible for any transaction that comes through regardless of whether it's "unauthorized"? Does anyone do this? Do you have a contract with the accountholder explaining all of this? Thanks for any information.

Since Reg E only applies to consumer transactions from consumer accounts, there is no laws (always check your state laws) that I am aware of that would provide protection for the business transactions you describe. Of course, be sure to review your agreements and don't give them an EFT disclosure.

I know Bankers Systems just yesterday gave me some promotional material on commercial debit cards. I haven't checked to see if they have designed a disclosure. You may want to check.

Kathryn,
We offer commercial debit cards to our business customers. We only have one EFT disclosure, which covers all of our electronic banking services, so we have designed a special section of that disclosure that pertains to commericial use.
I do not have that in a Word document, but if you want tosend me an e-mail with your fax number I will fax you a copy of our disclosure.
Leslie

We also currently offer Commercial Debit Cards. We had our bank counsel draw up a contract detailing the usage and liability. I always think its better to put these things in writing so that everyone is aware of their responsibilities up front.

We are about to roll-out commercial debit cards. In the process of researching this I discovered an interesting article regarding liability under UCC for business debit cards. I showed the article to our attorney and he agreed this is something which needs to be considered.
http://www.complianceheadquarters.com/Deposit/Drafting_Your_Business_Debit_C/drafting_your_business_debit_c.html