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#781930 - 07/24/07 08:24 PM Risk-based and Penalty price disclosure
someone else Offline
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someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
We are considering risk-based pricing for our next credit card program. Are there any special disclosure considerations?

Also, how do we disclose penalty pricing, when a consumer pays late more than a specified number of times?

Thank you!
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Lending Compliance
#782063 - 07/24/07 10:25 PM Re: Risk-based and Penalty price disclosure someone else
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,368
Galveston, TX
The implementing regulations for the risk based pricing disclosures required under FCRA have not yet been implemented (or proposed for that matter).
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