ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Uncategorized

Compliance question of the month: March 2025

Under risk-based pricing, when is "reasonably practicable" reasonable?

March 17, 2025
Reading Time: 1 min read
Compliance question of the month: February 2025

Q For purposes of complying with the risk-based pricing notices of Regulation V (Fair Credit Reporting Act), my bank uses the exception notice for its auto loans and boat loans. May that disclosure be provided with the closing package provided at consummation?

A It may, but only if it is not “reasonably practicable” to provide it earlier. The credit score exception notice permitted under §1022.74 (e)(3) must be provided to the consumer as soon “as reasonably practicable after requesting the consumer’s credit score but not later than consummation for closed-end credit or when the first transaction is made for open-end credit.” Thus, the basic requirement is that it be provided as soon as reasonably practicable, but after consummation is too late, even if that is “as soon as reasonably practicable.”

In the case of a boat or auto loan, especially if the loan is made quickly, it may not be “reasonably practicable” to provide the credit score prior to loan closing.

The same timing requirement applies to loans secured by residential real estate under §1022.74 (e)(3). However, given the typical length of time between mortgage loan application and consummation and the documents that must be provided prior to consummation, it is arguable that the notice should be provided prior to consummation.

For more information, contact ABA’s Leslie Callaway. Please note that this section is not a substitute for professional legal advice.

Tags: ComplianceFCRA
ShareTweetPin

Related Posts

Recent news from Treasury’s Office of Foreign Assets Control: April 5

Recent news from Treasury’s Office of Foreign Assets Control: January 20

Uncategorized
January 20, 2026

News items that are the most recent sanctions-related actions from the Office of Foreign Assets Control.

Recent news from Treasury’s Office of Foreign Assets Control: April 5

Recent news from Treasury’s Office of Foreign Assets Control: January 12

Uncategorized
January 12, 2026

News items that are the most recent sanctions-related actions from the Office of Foreign Assets Control.

Compliance question of the month: February 2025

Compliance question of the month: January 2026

Uncategorized
January 12, 2026

Compliance QOTM clarifies whether all loan renewals are reportable for CRA purposes.

Terrorism and money laundering aggregates published: April through June 2024

Terrorism and money laundering aggregates published: October through December 2025

Uncategorized
January 12, 2026

The FinCEN 314(a) Updates section is published on a periodic basis to better capture the trend line for 314(a) usage. The following is an update from October through December 2025.

ABA files amicus brief urging full Tenth Circuit to grant rehearing in Colorado rate opt-out lawsuit

ABA files amicus brief urging full Tenth Circuit to grant rehearing in Colorado rate opt-out lawsuit

Uncategorized
January 5, 2026

ABA filed a coalition amicus brief urging the Tenth Circuit to grant a rehearing en banc of a panel decision that reversed the District of Colorado’s preliminary injunction against Colorado’s rate opt-out law.

California federal court dismisses MiCamp Solutions’ antitrust lawsuit against Visa

California federal court dismisses MiCamp Solutions’ antitrust lawsuit against Visa

Uncategorized
January 5, 2026

Judge Haywood Gilliam of the Northern District of California dismissed a lawsuit alleging that Visa violated the Sherman Antitrust Act by monopolizing the card payment services market.

NEWSBYTES

Pending home sales fell in December

January 21, 2026

Survey: AI, fraud among top cybersecurity trends for 2026

January 21, 2026

ABA urges FDIC to pause special assessment collection

January 21, 2026

SPONSORED CONTENT

Seeing More Check Fraud and Scams? These Educational Online Toolkits Can Help

Seeing More Check Fraud and Scams? These Educational Online Toolkits Can Help

November 1, 2025
5 FedNow®  Service Developments You May Have Missed

5 FedNow® Service Developments You May Have Missed

October 31, 2025

Cash, Security, and Resilience in a Digital-First Economy

October 20, 2025
Rethinking Outsourcing: The Value of Tech-Enabled, Strategic Growth Partnerships

Rethinking Outsourcing: The Value of Tech-Enabled, Strategic Growth Partnerships

October 1, 2025

PODCASTS

Podcast: A Lone Star banking perspective

January 15, 2026

Podcast: The incredible shrinking penny (circulation)

January 8, 2026

Podcast: Cybersecurity in a mobile-first banking landscape

December 18, 2025

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.