We are currently creating a new product where the term of the loan the loan amount is based on the credit score. The rate is a fixed rate regardless of the term and loan amount. Are the term and loan amount considered “material less favorable terms” and a Risk Based Pricing Notice would be required?

Yes

For purposes of this definition, factors relevant to determining the significance of a difference in cost include the type of credit product, the term of the credit extension, if any, and the extent of the difference between the material terms granted, extended, or otherwise provided to the two consumers.