Must we notify the the owners of a DBA account of a change in terms according to Reg DD?

I say no, since the definition of consumer is:
(h) Consumer means a natural person who holds an account primarily for personal, family, or household purposes, or to whom such an account is offered. The term does not include a natural person who holds an account for another in a professional capacity.

But I have some here that disagree with me.

We don't provide DBAs with Truth in Savings disclosures because they don't fit the definition of "consumer". We do sometimes provide change in terms notices to commercial customers, but only as a customer service - not because of a regulatory requirement.

How you notify your commercial customers (including DBA accounts) of changes in terms is a matter of your contract with them, not of Reg DD. If your contract calls for some type of change in terms notice, then providing them with that notice isn't just a matter of courtesy, it's contract compliance.

Becca,

Waldensouth has hit this one on the head. If the account is held by a natural person, it's the purpose of the account that determines whether TIS applies. It doesn't apply to business-purpose accounts.