Answer:
Answer - John:I was involved in the earliest days of the regulation, and I don't recall any such provision. The underlying law is pretty specific in its application to consumer accounts.
There was some question about professional account holders. For example, there is a carve-out for accounts held by an attorney who acts in his/her professional capacity as a fiduciary for an individual, but not for a lay person who holds a similar account.
Answer:
Answer - Andy:Like John I was on the implementation team when Reg DD was proposed and effective. A "consumer" was defined then as it is now, a natural person and the account was for personal, family or household purposes. While some states may view a a husband and wife partnership as a sole proprietorship, that never transcended to Reg DD as the purpose of the account needs to meet the consumer definition.
First published on BankersOnline.com 5/24/10
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