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I have never read anything so difficult to understand in my life. I cannot figure what this is supposed to accomplish except to confuse the consumer even further and add to the bankers burden by adding more hardship and expense. It is very difficult and complex to understand just what customers are entitled to risk-based pricing notices. Some of the definitions appear to be open to different interpretations as to what they really mean. Such a lack of preciseness can only lead to varying and non-conforming practices as we try to create standards for notices. Perhaps the only saving grace might be the proposed exceptions. If this is allowed to pass at all, it must at least contain the exceptions.
Sharon J. Henson
|Last Updated 07/24/2008||Regs@fdic.gov|