I am immersed in the New Reg V provisions for Risk Based pricing notices and drawing a blank (feeling stupid! Finding it hard to analyze and keep track of more than one regulation at a time these days!). . .

I understand that we can give out the H-3 through H-5 notices to consumers who apply for loans, in lieu of the "credit score proxy" 60/40 notices). Would this go to all consumers who apply for loans--whether the loan is approved or denied, or just for the approvals? In which case, what notices do we now need to give for denials (the 609(g)notice under FCRA for real estate secured. . .etc.)?

Thanks. . .

One of the three exception notices would go to every applicant -- approved, denied, withdrawn, etc. That's the trade off for not having to do the "60/40" notices which don't have to be provided to denied, etc. applicants or to the top 40% of approved applicants.

And if you do provide the H-3 exception notice on all RE-secured applications, you're deemed to have complied with section 609(g) and the current Notice to the Home Loan Applicant (NTHLA) is dead. But remember, if you choose to provide a "60/40" notice, then you still have to proivde a NTHLA on RE-secured loans so some customers would be two disclosures.

Good luck.