The Risky Business of Risk-Based Pricing Notices

Our credit union regulatory compliance team is receiving a lot of questions about the recent risk-based pricing and adverse action notice changes. Part of the confusion stems from the fact that the risk-based pricing notice requirement is relatively new and has already been substantially revised. The Dodd-Frank Wall Street Reform and Consumer Protection Act mandated that credit score information be included in the risk-based pricing notices and Fair Credit Reporting Act adverse action notices. Consequently, the Federal Reserve changed the Regulation B model notices and Regulation V’s risk-based pricing notices.

Over the next few days, we will be answering some of the questions we are hearing most, which focus around these topics:

• Credit score exception notices
• Using credit score information on risk-based pricing notices
• Excluding credit score information from adverse action notices

If you have additional questions on this topic, feel free to post them and we will try to address them in future blogs.