Does anyone have an opinion...Do you have to provide a Risk Based Pricing Notice to a non-resident alien? I believe by the definitions of the regulation that you would, but we have pulled Canadian credit reports and the vendors (American vendors providing Canadian reports) are arguing that it does not apply. Any thoughts?

Thanks in advance.

Seems to me if you're doing a loan here the laws and regulations here would apply no matter where the borrowers were from.

Hold the vendors feet to the fire and ask them to provide chapter and verse that says it doesn't apply. When they can't, acknowledge that it's interpretation and you want your interpretation followed to cya.

I would bounce this to legal counsel, but the definition of consumer reporting agency does say it is for those who gather and report on a nationwide basis with no reference to international.

Reg Z does address applicability in its commentary, but I see no such reference here and no cross-definition to Z. Perhaps in an old FTC interpretive letter - and I have not looked.

Thanks for the feedback Truffle and KB. I've consulted with our legal counsel and they agree that we should probably provide the disclosure. We will require our service provider assist with the provision of the disclosure.

Thanks agian!