The new Risk Based Pricing rules under FCRA take effect January 1, 2011. And I know that there is a section on this topic in the Dodd-Frank Act.

Do I go ahead and prepare to be in compliance with the FCRA January 1 requirements? Or are there impacts from the Dodd-Frank Act that may change what becomes effective January 1 under FCRA?

Yes. I would not expect anything but maybe some tweaking if anything as a result of FD...It's just like an interim final rule whereby the FRB reserves the right to expand, etc, after a comment period, but the content in the IFR will apply, regardless, upon the effective date.

I'm envious of someone who is caught up enough to already be thinking towards January.

I just want to be sure I'm interpresting the Risk Based Pricing correctly. We do NOT request or use credit scores in any of our pricing decisions. Other factors on the credit report may (or may not) influence the pricing, though. Do I need to go crazy trying to conform to the Risk Based Pricing rules or don't they apply in this situation?

Based upon your post you may (or may not) need to go crazy. The coverage of the rule depends on whether you do risk-based pricing by using a consumer report, it is not limited to just using credit scores.