Since REG E does not apply to business accounts, we don't provide the REG E disclosure at account opening. We only provide a business card agreement with the business debit card but not at account opening. Is there a compliance requirement to provide something at account opening for business accounts?

Thanks,

Not from a federal regulatory standpoint.

Thank You. Is it required to provide a business card agreement with the debit card? We are thinking of not providing it anymore.

Then under what contractual conditions are you going to manage the business debit card if you are not going to give them an agreement? How would you hold them liable for anything? I highly suggest that you check with your card issuer, as I don't they allow you to issue cards without an established agreement.

You're right.....I wasn't thinking straight.
Thank You.