Recently the Federal Reserve Board and the Federal Trade Commission published final rules to implement the risk-based pricing provisions contained in section 311 of the Fair and Accurate Credit Transactions Act of 2003 (FACT Act), which amends the Fair Credit Reporting Act (FCRA). This final piece of the FACT Act requires all financial institutions to adopt new policies and new procedures to comply with the new risk based pricing requirements.
The final rules, effective January 1, 2011, require a creditor to:
- provide a risk-based pricing notice to a consumer when the creditor uses a consumer report to grant or extend credit to the consumer on material terms that are materially less favorable than the most favorable terms available to a substantial proportion of consumers from or through that creditor.
- provide for two alternative means by which creditors can determine when they are offering credit on material terms that are materially less favorable.
- include certain exceptions to the general rule, including exceptions for creditors that provide a consumer with a disclosure of the consumer’s credit score in conjunction with additional information that provides context for the credit score disclosure.
This program explains the new risk-based pricing rules inlcuding:
- Who is covered by the new requirements;
- An explanation of the menu of approaches that creditors may use to comply with the new requirements;
- Which terms are “material terms”;
- How to determine when material terms are “materially less favorable”;
- The three methods for determining which consumers must receive risk-based pricing notices;
- The new risk-based pricing notice - timing, content and exceptions;
- The revised credit score notice;
- The new notice required when no credit score is available; and
- The policies and procedures that each financial institution is required to adopt.
Workshop Resources: This program covers the FACT Act New Risk-Based Pricing requirements. Program participants receive a detailed manual, accompanied by a 1 hour 22 minute video webcast.
Expected Audience: The program is designed for compliance officers, auditors, security officers, and lending and operations personnel impacted by the changes.
| Speaker: Jack Holzknecht, is a principal with Pegasus Educational Services, LLC, a training firm headquartered in Louisville, Kentucky. He is an experienced consultant who has provided training to thousands of bankers and examiners for twenty-eight years. He has the ability to identify the key compliance issues from each regulation. Jack's career began in 1976 as a federal bank examiner. He later headed the form and software and education divisions of a regional consulting company. |
|
Printable_Brochure
View_Video_Introduction
Categories
