About the Program The Fair and Accurate Credit Transactions Act (FACT Act)
amended the Fair Credit Reporting Act to mandate the use of risk-based
pricing notices for consumers. The Dodd-Frank Act further amended the
Fair Credit Reporting Act to require disclosure of consumers’
actual credit scores and related information if a credit score is used
when taking adverse action or setting credit terms. As a general rule, a
credit union must provide risk-based pricing notices to consumers when
the credit union, based on a consumer credit report, either denies
credit or extends credit on terms that are materially less favorable
than the terms the credit union extends to other consumers.
However, there are important exceptions to this general rule and the
notice timing requirements vary depending on the specific type of
credit. This webinar will clarify situations where the credit union is
required to: 1) provide (and is prohibited from providing) these notices
and 2) disclose (and is prohibited from disclosing) the consumer’s
credit score. This program will clarify notice timing requirements for
specific types of consumer credit and review specific model notices for
each. Join us to learn the answers to all of your questions on these
Overview of risk-based pricing requirements, including a comparison
between Reg V and Reg B notices
If the credit score isn’t used to make or deny a loan, should
the credit score be included in the adverse action notice?
What if you pull a credit report, but don’t use the
consumer’s credit score in setting credit terms?
How can you prove to examiners that the credit score wasn’t
considered in making the credit decision?
Is a risk-based pricing notice required if all consumers are charged
the same rate for a specific loan type?
What if there are multiple debtors or multiple credit scores are
What if the consumer has no credit score?
Can you use the credit score of a guarantor or co-signer?
How do you determine the range of credit scores that must be
disclosed in the risk-based pricing notice?