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Compliance with the new risk-based pricing rule

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • March 31 2010

A new rule, issued by the Federal Reserve Board and the Federal Trade Commission, requires any company that uses a credit report or score in connection with a credit decision - including companies such as banks, mortgage bankers, auto lenders, retailers, and public utilities - to send notice to a consumer when, based on a credit report or score, the company grants credit on "material terms that are materially less favorable than the most favorable terms available to a substantial proportion of consumers."

Don’t forget the FCRA risk-based pricing rule

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • June 4 2010

In less turbulent times, the FCRA risk-based pricing rule would be a big deal, and a newsletter like ours might have even led with it

Mortgage disclosure clarifications

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • March 11 2011

The Board has issued a new interim rule clarifying parts of its original interim rule implementing certain disclosure provisions of the Mortgage Disclosure Improvement Act of 2008