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#1438634 - 09/02/10 08:54 PM Re: Risk-based pricing (FACTA 1/1/11) ahkcompliance
Compliance Chick Offline
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ahkcompliance, that is correct. If you don't give certain foks the risk based pricing notice, you give everyone the credit score disclosure.
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#1441684 - 09/10/10 09:30 PM Re: Risk-based pricing (FACTA 1/1/11) Compliance Chick
Here4Life Offline
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Has anyone figured out an "in-house" plan when you don't pull a new credit report but are relying on a "current" one in file?

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#1441696 - 09/10/10 09:44 PM Re: Risk-based pricing (FACTA 1/1/11) Compliance Chick
Sewanee, CRCM Offline
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TN
I may be overlooking or overthinking one issue. As I understand it, on a loan secured by 1-4 family residential real estate, if you issue the Risk Based Pricing Notice to those consumers who would need it, the "new" notice is combined with the currently required Notice to the Home Loan Applicant - two forms in one. However the RBPN is not required for those consumers who receive an Adverse Action Notice. But the Notice to the Home Loan Applicant is required regardless of whether the loan is approved or not - am I correct?

If you go the route of the exception notice (given to all), do you still provide it to customers who are declined?
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#1442117 - 09/13/10 06:56 PM Re: Risk-based pricing (FACTA 1/1/11) Sewanee, CRCM
Dazed Auditor Offline
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I believe the NTHLA still has to be provided to denied applicants. I have the same question on what is provided to the denied applicant if you are giving approved applicants the exception notice. What is everyone doing?
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#1442127 - 09/13/10 07:05 PM Re: Risk-based pricing (FACTA 1/1/11) Dazed Auditor
ccman Offline
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I believe you would provide the NTHLA and AAN as normal. The RBPN would be provided to borrowers who were approved, at least until we are told otherwise.

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#1445772 - 09/21/10 02:13 PM Re: Risk-based pricing (FACTA 1/1/11) ccman
GoBigRed Offline
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Somewhere
Under the timing requirements for a closed-end transaction, the rule states that the disclosure must be provided before consummation. When is a copy of the disclosure provided? When the customer receives the disclosure or when the disclosure is placed in the mail?
Last edited by GoBigRed; 09/21/10 02:14 PM.
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#1445843 - 09/21/10 03:23 PM Re: Risk-based pricing (FACTA 1/1/11) ccman
kristin09 Offline
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If you are giving the exception notice, I would give it to both denied and approved applicants because of the Notice To Home Loan Applicant information embedded in the form.

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#1448091 - 09/24/10 04:50 PM Re: Risk-based pricing (FACTA 1/1/11) Tigg
Tigg Offline
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Originally Posted By: Tigg
Originally Posted By: Ted Dreyer
The only thing that comes to mind is that you may want to start getting a credit score on all loans just for compliance purposes.


But how are examiners going to look at this? Will it cause fair lending issues?


*bump* smile

Is/has anyone gotten any regulator feed back on this? Thanks.
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#1448355 - 09/24/10 09:03 PM Re: Risk-based pricing (FACTA 1/1/11) Tigg
DD Regs Offline
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LEt me see if I hav ethis right:

If you go with RBPN, it does not go out to those who receive and AAN, but what about if you go with the Exception methods (H3,4,5), it doesn't make since that you would send it out to those who get the ANN?
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#1448450 - 09/27/10 03:41 AM Re: Risk-based pricing (FACTA 1/1/11) ahkcompliance
banker-12 Offline
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If we provide the exception credit score notice (H3, H4) to all customers - what is the low score and the high score under the range of scores section?

Under the next section (score range table)on the notice- I gather that Trans Union will provide this info for us - I found this info from their website. https://www.transunion.com/corporate/bus...sedpricing.page

Can we provide the risk based pricing notice (H1) to all consumers? We get a credit report for every consumer. This notice is much simpler than the others.

thanks,

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#1448484 - 09/27/10 01:07 PM Re: Risk-based pricing (FACTA 1/1/11) banker-12
Comply Wren Offline
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Sorry. The H1 cannot be offered to all consumers. See 222.72 and 222.73.

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#1448560 - 09/27/10 02:40 PM Re: Risk-based pricing (FACTA 1/1/11) banker-12
Ted Dreyer Offline
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banker-12: The low and high scores on the range of scores depend on which consumer reporting agency you use. They should already be provided on the Credit Score Disclosure that you give with the Notice to Home Loan Applicant for loan secured by 1-4 family real estate.

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#1448611 - 09/27/10 03:23 PM Re: Risk-based pricing (FACTA 1/1/11) Here4Life
bstritecky Offline
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Originally Posted By: Here4Life
Has anyone figured out an "in-house" plan when you don't pull a new credit report but are relying on a "current" one in file?


grinBump!

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#1448640 - 09/27/10 04:04 PM Re: Risk-based pricing (FACTA 1/1/11) bstritecky
banker-12 Offline
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Oh yes, the low and high score range is included on the credit score disclosure for 1-4 family real estate loans.

However, the credit report (TransUnion) we use for our consumer non real estate secured loans does not have a score range of low and high scores. Do you know if this is something they will start providing. From the article I read from the link I attached on my above post indicates that they will provide the percentile ranking, but theres nothing on the low and high scores.

thanks,

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#1448771 - 09/27/10 07:04 PM Re: Risk-based pricing (FACTA 1/1/11) bstritecky
Dan Persfull Offline
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Bloomington, IN
Originally Posted By: Becky S.
Originally Posted By: Here4Life
Has anyone figured out an "in-house" plan when you don't pull a new credit report but are relying on a "current" one in file?


grinBump!


Not sure what you mean by an in-house plan but the use of a previously acquired credit report for a new credit request does not fit the permissible use requirements.

This has not been widely enforced in the past but I wouldn't bet against that being changed since the risk based pricing should be based on current information, not past information.

Convincing management you shouldn't be doing this and getting the loan officers to break the habit is going to be one of the biggest challenges in changing how the credit reports are used.
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#1449041 - 09/28/10 01:34 PM Re: Risk-based pricing (FACTA 1/1/11) Sewanee, CRCM
DD Regs Offline
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Originally Posted By: sewanee
I may be overlooking or overthinking one issue. As I understand it, on a loan secured by 1-4 family residential real estate, if you issue the Risk Based Pricing Notice to those consumers who would need it, the "new" notice is combined with the currently required Notice to the Home Loan Applicant - two forms in one. However the RBPN is not required for those consumers who receive an Adverse Action Notice. But the Notice to the Home Loan Applicant is required regardless of whether the loan is approved or not - am I correct?

If you go the route of the exception notice (given to all), do you still provide it to customers who are declined?


Bump

I think this is right RBPN = No when denied
If Exception Notices = YEs send with AAN
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#1449044 - 09/28/10 01:38 PM Re: Risk-based pricing (FACTA 1/1/11) DD Regs
DD Regs Offline
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Somewhere in the middle
Also, seee if I have this right:

1. If an adverse action notice is given, customers DO NOT get a risk based pricing notice if we go with one of the RBPN methods. If we go with the Exception Notice route, it would still go out with the AAN.
2. If we use the RBPN, Loan reviews when a credit report is pulled and a score is obtained must also be provided the appropriate notice based on the type of credit that is being reviewed. (But what if we go the exception route? do they stil go out?)
3. If using the H-3, H-4 or H-5 exception forms. Under 222.75(c)(2) each person must get a separate exception form.
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#1449285 - 09/28/10 06:16 PM Re: Risk-based pricing (FACTA 1/1/11) DD Regs
Sewanee, CRCM Offline
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TN
It was pointed out on another thread that section 1100F of the Dodd-Frank Bill will require all declined applicants to receive a notice effective July 2011 (transfer date)the requirement to provide a notice to declined customers will be expanded.
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#1449395 - 09/28/10 09:07 PM Re: Risk-based pricing (FACTA 1/1/11) Dan Persfull
bstritecky Offline
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sd
Thanks Dan. You are so right!

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#1449403 - 09/28/10 09:39 PM Re: Risk-based pricing (FACTA 1/1/11) bstritecky
Jared Brown Offline
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I have a question:

If you are using the exception notice and you have a report that uses all three bureaus, will this require three separate exception notices or is there a model form that puts all three scores on one notice?

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#1449505 - 09/29/10 01:37 PM Re: Risk-based pricing (FACTA 1/1/11) Jared Brown
lmaizel Offline
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Posts: 90
Ohio
We purchased the BanersOnline CD "Implementing the New Risk-Based Pricing Regulations". Great CD. We think we are on the right track but have some questions.

Our Mortgage Lending Dept. utilizes risk based pricing. They will be providing the exception notice obtained from our Credit Reporting Bureau.

Our Consumer Lending Dept. does not utilize risk based pricing. We have 1 single APR for each product. All consumer customers with a score above a certain score threshold receive the same APR. Other factors may influence the credit decision but do not affect the APR. We believe we do not need to provide any type of notice to these customers unless the loan is a Home Equity Product. For those customers,we will continue to provide the Notice to Home Loan Applicant disclosure.

We have a few questions.
1) Do we have to provide the exception notice to all applicants regardless of the line of business or can we provide only to our Mortgage Loan customers?
3) Do you agree that for our consumer products the RBPN rules are not applicable?

Thanks for your help.

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#1449783 - 09/29/10 06:01 PM Re: Risk-based pricing (FACTA 1/1/11) Jared Brown
Jared Brown Offline
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Posts: 3
Originally Posted By: Jared Brown
I have a question:

If you are using the exception notice and you have a report that uses all three bureaus, will this require three separate exception notices or is there a model form that puts all three scores on one notice?


Found an answer to my question in case anyone else is interested. According to the Federal Reserve's document on the subject, you can provide a notice with an average of all scores, either the low, mid, or high score, or present all three scores on ONE notice.

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#1451751 - 10/05/10 03:59 PM Re: Risk-based pricing (FACTA 1/1/11) Jared Brown
ahkcompliance Offline
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Posts: 2,470
Midwest
Has anyone put together any training materials?

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#1454266 - 10/12/10 07:26 PM Re: Risk-based pricing (FACTA 1/1/11) Still Smiling
Here4Life Offline
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Posts: 116
Have you looked at Equifax's website yet? The Risk Based Pricing Notices are available, but I'm confused which one do we use if we have elected to use the exception notice(s)?

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#1454423 - 10/13/10 01:11 PM Re: Risk-based pricing (FACTA 1/1/11) Here4Life
J2C Offline
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Big Brother knows and that's a...
We have a point difference between our Tier I and Tier II rates. Say a customer qualifies for the Tier I rate and is approved at that rate by the bank. Then the dealer (indirect)decides to add additional points for whatever reason, which then raise the Tier I rate to be at or above the Tier II rate. Now we have a Tier I loan approval that is getting less favorable terms than a Tier II, do they get a notice? How would we handle this?
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