Identify triggers for sending a Risk-Based Pricing Notice
Apply the Direct Comparison and Credit Score Proxy calculation methods
Implement the Tiered Pricing Method for different pricing structures
Utilize the Credit Score Disclosure Exception to simplify compliance
Maintain proper timing for closed-end and open-end credit notices
Manage compliance requirements for account reviews and APR increases
In the world of lending, the difference between a "VIP rate" and a standard offer often comes down to a consumer's credit report. But what happens when a customer is charged more because of data they haven't seen? This course dives into the Risk-Based Pricing Rule, a critical component of the Fair Credit Reporting Act (FCRA) and Regulation V designed to ensure transparency in finance. When you grant credit on terms that are "materially less favorable" than those offered to others, the law requires you to tell the consumer why. This training equips you with the tools to handle the "Yes, but..." scenarios—where the loan is approved, but at a higher cost to the borrower.
We break down the complex calculation methods authorized by regulators, including the Direct Comparison Method, the Credit Score Proxy Method, and Tiered Pricing. You will learn how to set "cutoff scores" and when to send a Standard Risk-Based Pricing Notice to ensure consumers can check their reports for costly errors. To help you avoid logistical headaches, we also explore the "easy button" used by most lenders: the Credit Score Disclosure Exception. By providing every applicant with their score and the factors that affected it, you can streamline your workflow while remaining fully compliant with FTC and CFPB expectations.
Beyond the initial application, this course covers the "gotchas" of account reviews, where a drop in a long-time customer’s credit score might trigger a rate increase and a mandatory notice. We also provide best practices for automation, using CFPB Model Forms, and training frontline staff to handle sensitive customer questions. Whether you are an auto dealer, mortgage lender, or credit card issuer, understanding these timing and delivery requirements is essential to protecting your institution from regulatory scrutiny and empowering your customers to manage their financial health.
This program is available with Spanish and French closed captions.
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View this course in a classroom
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team individually with testing
and recordkeeping capabilities.
The rule is triggered when a lender uses a consumer report to grant credit on terms that are "materially less favorable" (usually a higher APR) than the best terms offered to a substantial number of other consumers.
It is a method used by most lenders to simplify compliance by providing a Credit Score Disclosure Notice to all applicants, regardless of their rate, instead of calculating who received "less favorable" terms.
For closed-end credit, the notice must be provided before "consummation," which is the point at which the consumer signs the final documents and becomes legally bound to the loan.
Yes; if an APR is increased during an account review based on a consumer report, a notice must be provided at the time the decision is communicated or no later than five days after the change takes effect.
The notice must include the actual credit score, the range of possible scores, the date the score was created, the key factors that adversely affected the score, and the name of the credit bureau.
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