Any time you're dealing with pricing of consumer credit, you should also keep the various non-discrimination prohibitions and UDAAP in mind. Reg. V tells you what to disclose when you have made a credit decision to extend credit on materially less favorable terms. It doesn't address the problem of arriving at your decision in an unfair or discriminatory manner. Let's say it's your practice to pull CBRs on all consumer credit applications--including applications secured by CDs or other cash-like collateral. In these cases, you didn't need the CBR because there is no risk, so any pricing differential becomes suspicious.