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RISK-BASED PRICING NOTICES
The FRB and FTC have released rules related to risk-based pricing practices by creditors that take effect 1/1/11; a notice is required when the creditor offers credit to the consumer on less favorable terms than it provides to other consumers. The FTC provides a sample (B-4) form for this purpose.I am curious what dealers and lenders are doing to comply with this new rule?See More
Rebecca Chernek commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"I will take a look at the link you provided thank you. I couldn't agree more dealers are tired of the regulations one after another but I don't think they will easy enough sweep this one under the carpet! Going to get interesting."
Robert W Linkonis Sr commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"Another thing - compliance with this rule is required by Jan 1, 2011. That deadline is almost here. Dealers that I have talked with think that the rule is just another waste of taxpayer dollars (which I agree with as well), bet federal law is…"
Robert W Linkonis Sr commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"Here is the link to Trans Union's solution: https://www.transunion.com/corporate/business/serviceSolutions/riskMgmt/factAct_riskbasedpricing.page . Funny, I can't find any mention of this rule on the Equifax site. Do they not want to offer…"
Rebecca Chernek commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"Going to be interesting. I assume NADA will take an active role to assure dealers are in compliance and companies like RouteOne or DealerTrack?"
Jason Buchanan commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"If a dealer offers varying terms, then they are subject to determining a Risk Based Pricing document. The varying terms exclusion is intended for lenders who only offer 1 rate to all consumers. So let's say I only offer 19% to all customers…"
Rebecca Chernek commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"This is huge on the dealer side! Dealers are always pulling credit to determine if the customer might get an approval or to discuss ball park payments. Can you clarify this for me please. What do you mean not offer varying terms depending on…"
Jason Buchanan commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"No notice of any kind is required if ...
-You offer credit on the same terms to every approved applicant (i.e., you
do not offer varying terms depending on applicant’s credit report)
-You don’t use credit reports in any way to make the…"
Lisa Soller commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"I am with a finance company that purchased installment contracts from dealers. We are NOT subject to the Risk Based Pricing Rule because we are an assignee on the contract and the dealer is the original creditor. Dealers must give the notice even if…"
Jason Buchanan commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"Let me also digress by stating that organizations may produce their own disclosures as well by incorporating the specific risk model distributions into their own templates. The Risk Based Pricing information that I am sharing are the general…"
Jason Buchanan commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"Please feel free to visit Experian's Risk Based Pricing information site. http://www.experian.com/consumer-information/risk-based-pricing-rule.html Basically, under the new rule, lenders must provide consumers with a Risk-Based Pricing notice…"
Rebecca Chernek commented on Dave Davis's blog post RISK-BASED PRICING NOTICES"I am all ears too! What are the steps dealers are taking to comply with this law and how many dealers even know about it? Excellent question!"
RISK-BASED PRICING NOTICES
The FRB and FTC have released rules related to risk-based pricing practices by creditors that take effect 1/1/11; a notice is required when the creditor offers credit to the consumer on less favorable terms than it provides to other consumers. The FTC provides a sample (B-4) form for this purpose.I am curious what dealers and lenders are doing to comply with this new rule?See More
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- First & Last Name
- Dave
- Corporate Title
- Business Development Executive
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- Legacy Community Federal Credit Union
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- Credit Union
- City, ST
- Birmingham, Alabama
Dave Davis's Blog
RISK-BASED PRICING NOTICES
Posted on November 5, 2010 at 12:40pm 12 Comments 0 Likes
The FRB and FTC have released rules related to risk-based pricing practices by creditors that take effect 1/1/11; a notice is required when the creditor offers credit to the consumer on less favorable terms than it provides to other consumers. The FTC provides a sample (B-4) form for this purpose.
I am curious what dealers and lenders are doing to comply with this new rule?
Comment Wall (1 comment)
- At 6:23pm on October 4, 2010,
Glenn S. Gottfried said… - Dave,
It is my hope that 2010 ends well for you, your organization and our industry. I would like to introduce you to my company, GripFin, Inc., which provides advisory and investment services to auto portfolio buyers and sellers of all sizes and credit spectrums. I would appreciate your visiting my profile and inviting me to become your friend. Thanks, Glenn Gottfried, CEO, GripFin, Inc.
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