Opening New Business Account (Reg CC Guidelines)

Question:

I have two customers, Harry and Larry, that have had checking accounts with our bank for more than 30 business days prior to opening a new business account titled xxxxxx LLC. Would this be considered a new account per Reg CC guidelines since the business has not had any accounts with our bank?

Answer:

XXX LLC is a new customer; the exception hold, properly disclosed, would be available to you.

If Harry or Larry opened a new account the hold would not be available. If they had described this hold accurately, it would have been the "new customer" not the "new account" exception hold.