Answer:
Answer by Randy Carey: 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 David Dickinson:I agree with Randy. Over-disclosure does not make you bound to Reg Z. However, if you tell a customer something, you should be accurate. You may have a legal issue on your hands otherwise. At best, a customer service issue.
First published on BankersOnline.com 1/31/11
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