FRB and FTC Issue Final Risk-Based Pricing and Adverse Action Rules

The FRB and the FTC issued final rules implementing Dodd-Frank’s credit score disclosure requirements, amending their January 10, 2010 interim risk-based pricing rules to require disclosure of credit scores and information relating to credit scores in risk-based pricing notices if a credit score of the consumer is used in setting the material terms of credit.  If a credit score is used in setting material terms of credit or in taking adverse action, the statute requires creditors to disclose credit scores and related information to consumers in notices under FCRA.  The final rules amend Reg. V to revise the risk-based pricing notices’ content, and to provide model forms.  The rules also amend model notices found in Reg. B, which combine the adverse action notice requirements for Reg. B and the FCRA to reflect the new credit score disclosure requirements.  The rules under Regs V and B will become effective 30 days after publication in the Federal Register.

The Risk Based Pricing Rule can be found here and the Adverse Action Rule can be found here.