If we perform an account review on a credit card or HELOC and increase the APR, do we have to provide the RBP Notice or can we just provide the Consumer Credit Score Disclosure exception notice?

Thanks in advance for your help!

HELOC and increase the APR.

Well let's start with the fact that you can't raise the APR on a HELOC once the loan has closed based on a credit report.

Ok, that's how little I know about HELOCs ...but what about credit cards?

In the appropriate circumstances for account review and increase of an APR does it trigger a RBP notice or can an exception notice be used?

You might want to start here:

http://www.bankersonline.com/regs/12-1026/12-1026-055.html

and here - paragraph D:

http://www.bankersonline.com/regs/12-1022/12-1022-072.html

and both of these regarding adverse actions:

http://www.bankersonline.com/regs/12-1002/12-1002-009.html

http://www.bankersonline.com/regs/fcra/fcra.html#615

Seek and you shall find...The FED's FCRA procedures state: Regardless of whether the institution provides risk-based pricing notices or credit score exception notices, if the institution increases the customer's APR as a result of a review of the consumer's account, determine whether the financial institution provided the consumer with an account review risk-based pricing notice if an adverse action notice was not already provided.

Thanks, rlcarey, for your help. I'll take a look at these. Have a great day!