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How Does Reg E Apply To A Business

Question: 
How does Reg E apply to a Business? We are thinking about offering debit cards to our business customers. Does Reg E only apply to consumers regarding the liability and chargeback rights on debit cards?
Answer: 

Answer by Brian Crow: Reg E does not apply to business cards. However, VISA/MasterCard Zero Liability protections and chargeback rights to apply to small business debit cards issued to businesses with less than $10 million in annual revenue.

Answer: 

Answer by Andy Zavoina: Reg E applies to accounts used for personal, family and household purposes. I believe it is important that when a stack of brochures/disclosures is handed to a new account business customer that your Reg E be omitted or clearly defined as not applicable. I can see otherwise a UDAAP or breach of contract claim as the commercial account owner would say "but they told me in this disclosure that my liability was limited to..."

You should have a separate disclosure defining the contract rights under your terms (including Visa/MasterCard) with the commercial account.

First published on BankersOnline.com 7/08/13

First published on 07/08/2013

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