Answer:
Answer by Randy Carey: 1026.3(a) Business, Commercial, Agricultural, or Organizational Credit
1. Primary purposes. A creditor must determine in each case if the transaction is primarily for an exempt purpose. If some question exists as to the primary purpose for a credit extension, the creditor is, of course, free to make the disclosures, and the fact that disclosures are made under such circumstances is not controlling on the question of whether the transaction was exempt.
Answer:
Answer by Richard Insley: Even though erroneous delivery of TIL disclosures does not subject an exempt transaction to Regulation Z, the language of your consumer notes and TIL disclosure documents may create more favorable terms than you ordinarily grant to commercial customers.
Answer:
Answer by Jim Bedsole: It becomes a matter of contract law. Your business customer may be able to assert that you contracted for the terms in the consumer disclosures and are now bound to those terms.
First published on BankersOnline.com 3/4/13
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