Implementing the New Risk-Based Pricing Regulations


Financial Institutions + Financial Services

Rick Fischer

Rick Fischer


Elizabeth B. Frank
(212) 336.4225

Topics to include:

• Who is covered by the new requirements?
• Various approaches that financial institutions may use to comply with the new requirements;
• What are "material terms" & how to determine when they are "materially less favorable";
• What is a “substantial proportion” of your consumers;
• Compliance methods used for determining which consumers must receive risk-based pricing notices;
     o When & how to issue a new risk-based pricing notice, including:
     o The required content of the notice;
     o Form of the notice;
     o The timing of the notice; and
     o The exceptions to use of the notice.

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