I had asked this before and also read in the latest "Consumer Compliance Outlook" that if the same rates are charged to all approved applicants (consumer and commercial under $1,000,000) for a particular product, no RBP or exception notice is required for approved applicants, but an adverse action notice is still required for denied applicants. Two questions..
1) So the exception notice need not be sent with the denial?
2) My bank charges the same rate for certain product, amount, etc... BUT gives additional discounts for length of relationship, other loans, and account balances. These discounts are the same for all approved applicants. Do these approved customers not receive the RBP notice or exception notice, or do the discounts matter in this case?

1. This will depend how quickly you provide the AAN. You have to provide the exception notice as soon as reasonably practicable after obtaining the credit information. So if you are sending out your AAN within 3 to 5 business days an exception notice would not be required. If you are mailing them out 7 business days or longer you should have already provided the exception notice.

2. This is relationship pricing, not risk based pricing. A RBPN or exception notice would not be required.

if the same rates are charged to all approved applicants (consumer and commercial under $1,000,000) for a particular product, no RBPN or exception notice is required for approved applicants,

If you charge the same rate to all approved applicants then you are not risk base pricing therefore the Risk Base Pricing Notice or exception notice would not be required.

The RBPN or exception notices do no apply to business purpose credit regardless of loan amount or the size of the business.