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We are putting together account disclosures for business and consumer debit cards, specifically regarding error resolution under Regulation E. While Regulation E does not apply to business accounts, is there an Illinois law that might apply to business debit cards? – IBA Compliance Connection

IBA Compliance Connection

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We are putting together account disclosures for business and consumer debit cards, specifically regarding error resolution under Regulation E. While Regulation E does not apply to business accounts, is there an Illinois law that might apply to business debit cards?

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No, we are not aware of any Illinois laws that would impose error resolution requirements on a business debit card. Moreover, as you note, Regulation E applies only to consumer-purpose accounts.

However, we do recommend consulting with your bank counsel when drafting the account disclosures for your business debit card customers. In addition, as you draft the disclosures, you should review any MasterCard or Visa rules and disclosure requirements that may apply to the business debit cards.

For resources related to our guidance, please see:

  • Regulation E, 12 CFR 1005.2(b)(1) (“‘Account’ means a demand deposit (checking), savings, or other consumer asset account . . . established primarily for personal, family, or household purposes.”)