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Risk-Based Pricing Notice Template
Risk-Based Pricing Notice Template FAQ
What is a risk-based pricing notice?
A risk-based pricing notice is a consumer notice used when a creditor uses a consumer report and, based in whole or in part on that report, offers credit on material terms that are materially less favorable than the most favorable terms available to a substantial proportion of other consumers. CFPB Regulation V also provides model forms for these notices, including versions used when a credit score is part of the pricing decision.
Why do you need a risk-based pricing notice?
You need a risk-based pricing notice to inform the consumer that consumer-report information affected the terms offered and to tell the consumer about the right to review and dispute report information. The rule also requires key disclosures such as the reporting agency information, how to obtain a free report, and, when applicable, credit score details.
When should you use a risk-based pricing notice?
Use this notice in consumer credit situations when the rule applies and the creditor is offering materially less favorable credit terms based on consumer report information. Under the regulation, timing generally depends on the credit product, but for closed-end credit the notice is generally provided before consummation, and for open-end credit before the first transaction; the rule also includes exceptions and alternative compliance methods in some situations.
How to write a risk-based pricing notice?
Start with the creditor and consumer details, then state that consumer-report information affected the credit terms offered. Include the consumer reporting agency details, explain the consumer’s right to obtain a free report and dispute inaccuracies, and add the CFPB information reference. If a credit score was used in setting the material terms, include the score used, score range, key adverse factors, score date, and the source of the score.
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