FACT Act Risk-Based Pricing Rule #534730-00004

Submission Number:
534730-00004
Commenter:
Jeff Stewart
Organization:
Bank of Frankewing
State:
TN
Initiative Name:
FACT Act Risk-Based Pricing Rule

This is a complex and difficult rule to understand. The typical institution will have difficulty understanding what customers are entitled to risk-based pricing notices. Many of the "definitions" appear to be open to different interpretations as to what they really mean and that such lack of precision will lead to varying, possibly non-conforming, practices as institutions use those imprecise difinitions to create standards for rendering notices. Thankfully, the "exceptions" provided will allow us, as lenders, to live within the spirit of what Congress seemed to intend when it crafted this part of the FACT Act. I urge you to make the rule clearer without removing the exceptions provided.