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Reg E Discl. Given to Business Acct.

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Can you go over the Reg E disclosure given to businesses? What is their liability?

The bank should either NOT give Reg E disclosures to a business or if given in bulk with other disclosures should clearly define it is not applicable to all accounts and does not apply to accounts used for business purposes. Doing so can imply there are protections which Reg E does not offer, potentially making the bank liable for Reg E-like protections and exposing the bank to UDAAP/UDAP violations. Reg E provides no liability guidance for a business account. That would call for a separate agreement such as under Visa or Mastercard rules for business accounts.

First published on 11/14/2021

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