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#1793542 - 03/11/13 08:56 PM Risk based pricing
regreader Offline
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regreader
Joined: Oct 2002
Posts: 14
Greene Co., TN.
We're a small community bank that curently maintains a single loan pricing sheet for all branches to use. We supply the exception risk based pricing notices to all. A question has come up as to whether we can establish a separate loan pricing sheet by county. Would this be considered as risk-based pricing?

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#1793544 - 03/11/13 09:01 PM Re: Risk based pricing regreader
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,679
Galveston, TX
Risk based pricing is based on the credit risk of the individual borrowers.

If you mean can you have separate pricing for different counties, that is a totally separate issue.

If you do, it should be well documented as to the reasons, i.e., documented competitive pressures, etc., especially if the demographics between the counties are different. A higher price in a county with a higher minority population or customer base might lead to a disparate impact.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1797738 - 03/22/13 07:50 PM Re: Risk based pricing regreader
DoorKey Offline
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Joined: Nov 2002
Posts: 228
Wisconsin
If you do provide a risk based pricing notice, must the institution maintain a copy in its records, and if so, for how long?
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#1797801 - 03/22/13 09:17 PM Re: Risk based pricing regreader
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,679
Galveston, TX
There are no retention requirements in the regulation.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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