We are planning a promotion that advertises "Free Business Checking". This will be a small business account that provides the customer with their first 200 items free before any fee is charged. The limit will be stated in the advertisement. I believe the use of the word free would be prohibited by Reg DD if this were a consumer account. Can anyone tell me if this is a problem when advertising a business account?

I would look toward your State's laws regarding unfair and deceptive advertising practices. Many States also regulate the word "free" in advertisements.

Regulation DD does not apply to business accounts. But do note Randy's comment above. Some state's UDAP laws apply to more than just consumer accounts.

You should also compare your suggested ad with the "free" business checking against the FTC Guidelines on the use of the word "free" in marketing materials.

Whenever you do any campaign with the word "free" you need to not only look at any applicable banking regulations but also state law on unfair business/deceptive practices and federal consumer protection law (FTC Guidelines) to make sure your ad carefully navigates all applicable laws.