Learn to navigate Regulation V, determine materially less favorable terms, and master the Credit Score Disclosure Exception.
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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