We use the "exception" notices for credit score disclosures. Did those change? Our forms vendor sent new risk based pricing notices but I'm thinking those just replace the actual RBP notices and not the exceptions. These were all in with the new notices for the adverse action. I'm just trying to make sure that the exception notices did not change.

The way I understand it, the Reg. V risk based pricing notice changes only affect institutions that use credit score proxy, tiered pricing, or direct comparision for their risk-based pricing method.

If you utilize the exception notices for risk-based pricing purposes the rules have not changed.

That is my understanding as well. I spoke with our credit reporting agency today (they send out the H-3 notices to all applicants) and they confirmed their compliance area has indicated the Exception Notices will not change.