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#1689363 - 04/17/12 02:51 PM Help with question please...
avpbanker64 Offline
Member
Joined: Apr 2012
Posts: 56
Kentucky
We use a Credit Score Exception Notice in lieu of a Risk Based Pricing Notice. Our bank offers a Visa Credit Card application as a take-one application. If an applicant is approved are we required to give a Credit Score Exception Notice to them? I found something in Reg. V Subpart H Section 1022.72 that makes me believe we are not required. By the way, we offer 2 types, a Gold and Classic card with an Introductory Rate for 6 months and after that time period goes to a fixed rate.

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#1689367 - 04/17/12 02:59 PM Re: Help with question please... avpbanker64
RR Joker Offline
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Posts: 20,656
The Swamp
Are your rates tiered? Are they driven by the person's credit or credit score? Or, is it the same for everyone.
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#1689382 - 04/17/12 03:18 PM Re: Help with question please... RR Joker
avpbanker64 Offline
Member
Joined: Apr 2012
Posts: 56
Kentucky
Our APRs are not tiered and not driven by the person's credit or credit score. If you are approved, the loan officer will either give you a Gold Card or a Classic Card, the difference is the credit limit amount available and the rate.
For Instance: Intro Rate on both is 6.90% but the Fixed Rate after 6 months is 12.90% Classic and 10.90% Gold. Thanks for your help.
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#1689496 - 04/17/12 04:55 PM Re: Help with question please... avpbanker64
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
AH! So, truly your rates ARE tiered. Look at what you have written!

So...if they are not considering credit...what are they considering to decide whether to give you Classic or Gold?
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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1689502 - 04/17/12 05:03 PM Re: Help with question please... avpbanker64
avpbanker64 Offline
Member
Joined: Apr 2012
Posts: 56
Kentucky
Yes. I did not consider these tiered rates since the Intro Rate is for 6 months and then the Rate is Fixed and never changes. Does anyone give these disclosures to Credit Card applicants?
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#1689506 - 04/17/12 05:10 PM Re: Help with question please... avpbanker64
Tesla Offline
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Joined: Nov 2003
Posts: 3,726
Yes- if they do not get the top tier (we have four tiers), they get a RBPN.
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