[Al1]

I believe UDAAP only pertains to consumers and from what I've learned from regulators and the lobbyists that interact with them, small businesses never fall into the category of consumers, not even if it's a 1 man sole proprietorship.

The UDAAP regulations are some of the only federal laws that apply to commerce with consumers as well as businesses. FTC enforcement actions involving consumer transactions are much more common, but B2B transactions are subject to the UDAAP rules.

I think Heather's comment highlights exactly what the FTC would be looking for, which is disclosure. The FTC isn't concerned with rates or fee amounts. It just wants to make sure this information is being communicated clearly to the borrower/seller and is not being misrepresented, like you mention.