FCRA

Question 1

When must a credit union provide a risk-based pricing notice?

Answer 1

Credit unions are required to provide a risk-based pricing notice when: (1) the credit union uses a consumer report in connection with a consumer’s credit application or extension; and (2) based at least in part on that report, grants or extends credit to the consumer on “material terms” (e.g., annual percentage rate or APR) that are “materially less favorable” (higher cost for credit) than the most
favorable terms available to a substantial portion of the credit union’s members.