Since Reg E does not apply to commercial accounts,is there any other law or reg that would prevent us from mailing unsolicited debit cards. Of course they would require activiation by the business.

Food for thought:

Because Reg E does not cover Business Debit Cards, you would be wise to have your business customers sign an agreement with you. This agreement would clearly state the features of your program and any remedies that you may or may not offer them.

You might also think about who opens the mail at many businesses. It usually is NOT the business owner. Do you really want to send unsolicited cards this way?

You will have an issue under Reg Z if the debit card accesses an overdraft line tied to the checking account. Remember this is one of the exceptions to the rule that Reg Z applies only to consumer credit. See the commentary to 226.12.