Compliance Question of the Week
Do I have to provide a Risk-based Pricing Notice with the pre-approved credit card offers we send out?
May 17, 2011
Do I have to provide a Risk-Based Pricing Notice with the pre-approved credit card offers we send out?
No. You are not required to provide a risk-based pricing notice to a member if the member is applying for a specific term—such as you send out pre-approved offer to a member for a 10 percent APR credit card. The member would be receiving that rate and you would not need to send the notice.
However, if you send the firm offer of credit for rates between 8 to 12 percent, then you would need to send Risk-based Pricing Notices to the members who do not get the cards with the best rates. The Risk-Based Pricing Notice would need to be included with the account opening disclosures you sent to the member who did not qualify for the best rate.
12 CFR 222.74
Questions? Contact the Compliance Hotline: 1.800.546.4465, [email protected].