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?

Can anyone help?

If you are going to use the exception notice instead of the Risk Based Pricing Notice then review 1022.74(e).

So, even if we are risk-based pricing we can send the exception notice? Then why even have form H-6?

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.

And yes, the exception notice can be used for all products.