Some of the additional information that financial institutions might be required to disclose in risk-based pricing notices could confuse or mislead consumers, NAFCU wrote in a comment letter to the Federal Reserve.
NAFCU Associate Director of Regulatory Affairs Dillon Shea wrote that statements on the Fed's model forms such as "your credit score can change, depending on how your credit history changes" are obvious to most consumers and unnecessarily increase the size of the disclosure.
Shea also wrote that providing the range of the credit score is "of little actual benefit,'' since the consumer's score is already required to be on the form.
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