To date, my bank has not done risk based pricing and beginning 1/1/11 we have been providing the Credit Score Disclosure (Model Forms H-3 and H-4).

Now, management wants to explore risk based pricing for automobile loans. I am so turned around that I don't know if we have to then provide the Risk Based Pricing Notice under 222.72(a) or if we are still covered under the exception in 222.74(e) and we need to continue with the Credit Score Disclosure.

Can anyone get me straightened out?

If your pricing (APR) of loans does vary, then you have the choice of either A or B:

A) Tracking comparable loans and APRs & recalculating every 6mo . . . 222.72(a). Why would any bank do that?

B) Using the exception 22.74(e) = Credit Score disclosure / information & use model forms H-3; H-4; and H-5.

Is your bank going to develop a tiered pricing method? If so, providing the RBPN is not as difficult. We use a 5 tiered pricing method and only have to have the H-1 to borrowers who are in tiers 3 through 5. The form is only one page, and is hardcoded with all the CB info, so it's just a print and hand out thing.

I believe we will have the tiered pricing method. I was thinking too that I just have to provide RBPN H-1 instead of the Credit Score Disclosure.

Thanks for your help.