TISA and Reg E Disclosures on Business Accounts

Posted By: Anonymous

TISA and Reg E Disclosures on Business Accounts - 03/23/21 03:15 PM

Do any of you provide these on business accounts? It seems to me even if they are marked "applies to consumer accounts only" it can create confusion. I think the thought process, particularly on the TISA, is so the business customer is aware of the interest rate/account parameters, but I don't want to bind us to the same practices on consumer accounts that are not required on business/commercial customers.
Posted By: Skittles

Re: TISA and Reg E Disclosures on Business Accounts - 03/23/21 03:18 PM

We do not supply these on business accounts.
Posted By: Bankwoman1

Re: TISA and Reg E Disclosures on Business Accounts - 03/23/21 03:21 PM

Same here. We do not provide these on business accounts.
Posted By: P*Q

Re: TISA and Reg E Disclosures on Business Accounts - 03/23/21 03:50 PM

Definitely not.
Posted By: ACBbank

Re: TISA and Reg E Disclosures on Business Accounts - 03/23/21 04:55 PM

We don't either. I thought the TISA applied to consumer only? We still disclose the interest rate & TCs of our business accounts though.
Posted By: Anonymous

Re: TISA and Reg E Disclosures on Business Accounts - 03/23/21 06:52 PM

Thanks, all (original anon here). ACBbank - yes, TISA does apply to consumer only so that was my concern that it can be confusing to give that disclosure to business customers. So are you saying you disclose rate, min bal, etc. within your terms and conditions documents on business accounts?
Posted By: John Burnett

Re: TISA and Reg E Disclosures on Business Accounts - 03/29/21 07:28 PM

Your business customers need that information as to costs, etc. What they don't get (and should not be confused to think they do get) are the consumer protections that come with Reg E, in particular, but Reg DD, too.
Posted By: Anonymous

Re: TISA and Reg E Disclosures on Business Accounts - 03/29/21 09:03 PM

Originally Posted by John Burnett
Your business customers...don't get (and should not be confused to think they do get)...consumer protections that come with Reg E, in particular, but Reg DD, too.

Another anon here but...I've raised this issue, oh, half a dozen times. It has not been acted upon. Can anyone advise any tips for persuading those with the power to effect change, exactly how big and bad this issue is? I've come to think we're going to have to take a loss of at least $10,000 before someone finally realizes I've been bringing this up for 2 years.