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#2053890 - 12/11/15 10:01 PM Risk-based price notice form H-4
cloudy Offline
Junior Member
Joined: Apr 2009
Posts: 35
Our bank wants to start doing risk-based pricing for direct auto and unsecured loans. Compliance has advised that we should use model form H-6 for this. Our systems can not send out model form H-6 for only those products and the exception notice for all other products. Can model form H-4 be used for all products, even the ones where we are risk-based pricing to loan?

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#2053947 - 12/14/15 02:12 PM Re: Risk-based price notice form H-4 cloudy
cloudy Offline
Junior Member
Joined: Apr 2009
Posts: 35
Can anyone help?

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#2053979 - 12/14/15 03:43 PM Re: Risk-based price notice form H-4 cloudy
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,958
Bloomington, IN
If you are going to use the exception notice instead of the Risk Based Pricing Notice then review 1022.74(e).
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2053985 - 12/14/15 04:10 PM Re: Risk-based price notice form H-4 cloudy
cloudy Offline
Junior Member
Joined: Apr 2009
Posts: 35
So, even if we are risk-based pricing we can send the exception notice? Then why even have form H-6?

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#2054006 - 12/14/15 04:51 PM Re: Risk-based price notice form H-4 cloudy
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
Not all banks send the exception notice, which goes to everyone. They have chosen to use the H-6 and only send in the circumstances required.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2054008 - 12/14/15 04:52 PM Re: Risk-based price notice form H-4 cloudy
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
And yes, the exception notice can be used for all products.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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