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
ADVERTISEMENT
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.

ADVERTISEMENT
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: June 16

Uncategorized
June 16, 2025

The Office of Foreign Assets Control announced the following sanctions action last week.

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

Recent news from Treasury’s Office of Foreign Assets Control: June 9

Uncategorized
June 9, 2025

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

Preliminary injunction denied in bid to delay Capital One’s Discover purchase

Preliminary injunction denied in bid to delay Capital One’s Discover purchase

Uncategorized
June 2, 2025

A California federal court denied a group of consumers’ motion for a preliminary injunction seeking to delay Capital One’s impending purchase of Discover.

Third Circuit reverses FCRA lawsuit against Nissan over lease dispute

Third Circuit reverses FCRA lawsuit against Nissan over lease dispute

Uncategorized
June 2, 2025

A unanimous Third Circuit panel reversed a New Jersey federal court decision and ruled that a jury could find Nissan’s credit reporting inaccurate and its investigation unreasonable under the FCRA.

Green Dot agrees to pay Federal Reserve $44 Million to resolve UDAP allegations.

ABA, co-plaintiffs file joint motion with Federal Reserve to stay proceedings in stress test lawsuit

Uncategorized
June 2, 2025

ABA and its co-plaintiffs filed a joint motion with the Fed to stay proceedings in their lawsuit claiming the Fed’s stress testing framework violates the APA.

U.S. Supreme Court vacates Ninth Circuit preemption decision

U.S. Supreme Court clarifies wire fraud liability

Uncategorized
June 2, 2025

In a unanimous decision, the U.S. Supreme Court ruled a defendant may be convicted of federal fraud for inducing a victim to enter into a transaction under materially false pretenses, even if the defendant did not intend to...

NEWSBYTES

ABA DataBank: Planned/announced office conversions spike

June 20, 2025

OCC releases mortgage performance report for Q1 2025

June 20, 2025

Justice Department seizes millions of dollars linked to alleged crypto investment scams

June 20, 2025

SPONSORED CONTENT

AI Compliance and Regulation: What Financial Institutions Need to Know

Unlocking Deposit Growth: How Financial Institutions Can Activate Data for Precision Cross-Sell

June 1, 2025
Choosing the Right Account Opening Platform: 10 Key Considerations for Long-Term Success

Choosing the Right Account Opening Platform: 10 Key Considerations for Long-Term Success

April 25, 2025
Outsourcing: Getting to Go/No-Go

Outsourcing: Getting to Go/No-Go

April 5, 2025
Six Payments Trends Driving the Future of Transactions

Six Payments Trends Driving the Future of Transactions

March 15, 2025

PODCASTS

Podcast: Staying close to clients amid tariff-driven volatility

June 18, 2025

Podcast: Old National’s Jim Ryan on the things that really matter

June 12, 2025

Podcast: What bankers need to know about ‘First Amendment audits’

June 5, 2025
ADVERTISEMENT

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

© 2025 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

© 2025 American Bankers Association. All rights reserved.