Thread Starter: EmilyAnn
Title: Re: Card Denials and Risk-Based Pricing Notices
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See the coverage section of the final rule:
640.1 Scope. (a) Coverage—(1) In general. This part applies to any person that both—
(i) Uses a consumer report in connection with an application for, or a grant, extension, or other provision of, credit to a consumer that is primarily for personal, family, or household purposes; and
(ii) Based in whole or in part on the consumer report, grants, extends, or otherwise provides credit to the consumer on material terms that are materially less favorable than the most favorable material terms available to a substantial proportion of consumers from or through that person.
The original question asked about debit or ATM cards, not credit cards. A debit or ATM card is not an extension of credit. If linked to an overdraft line of credit, you may have a case in which you would need to provide an Adverse Action Notice with the Reg B/ECOA information if you turned it down. I won't opine on that since I don't have details on whether such a program is in place and how it works. But you would not, for the debit or ATM card itself, provide a risk-based pricing notice, even if an overdraft line of credit is involved. Note also in the definition that the RBPN specifically applies to those instances in which credit is actually provided - NOT in adverse action situations.
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