For existing card accounts and account reviews for risk-based pricing, can you raise the rates on existing account balances? Or does it apply only to new balances?

The rule does not seem to address this, so I would view it that that could occur. Whereas penalty-based pricing goes to new accounts under the UDAP changes.

Correct? Thanks.

Model Form H-2 in the new Risk Based Pricing = The directions for this form indicate it is to be used for an "Account Review". It gives the example of a credit card, but I would suspect there are other accounts where the "loan" continues but is subject to periodic reviews.
I believe some HELOC programs would fit here = we have reviewed and because . . . LTV is now X; your DTI is now Y; etc... your new rate / APR is Z.

We have a bit of a twist to this question.

If we are pulling a "soft pull" to perform the account review, must form H-2 be sent?

Our vendor says, "You are not required and actually suggested not to have the disclosure print up on the soft pulls." But it just is not sitting right with me.

The report you are using still falls within the definition of a consumer report therefore the disclosure requirements for its use would apply.

Dan,
We would use this report to simply extend the line without any APR changes. Would we still use H-2 in your opinion? That section of the Reg seemed to me to imply that it was only for APR increases.

If no negative action (increased rate) is taken the disclosure requirements for its use do not apply.

If you are reviewing an account, the only time you are required to send a notice would be if due to their report, you increase the rate...is that correct? The regulation only mentions credit card accounts.

The real gist of my question is...this does NOT apply to freeze or reductions in credit lines does it? That's an AAN, but is RBP notice required??