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Protect Your Dealership with RouteOne’s Risk-Based Pricing solution
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R1 risk based_pricing
1.
Don’t Be Caught
off guarD Protect Your D ealershiP with routeo ne’s r isk-BaseD Pricing solution RISK-BASED PRICING RULES DEFINED The Board of Governors of the Federal Reserve System and the Federal Trade Commission (FTC) jointly issued the Risk-Based Pricing Regulations to implement the risk-based pricing provisions in section 311 of the Fair and Accurate Credit Transactions Act of 2003 (‘FACT Act’) which amends the Fair Credit Reporting Act (‘FCRA’). The Risk-Based Pricing Rules generally require a creditor (in most cases this term includes dealers when entering into financing transactions with their customers) to provide a risk-based pricing notice to a consumer when the creditor uses a consumer report to grant or extend credit to the consumer on material terms (generally meaning the APR) that are materially less favorable than the most favorable terms available to a substantial proportion of consumers from or through that creditor (dealer) in connection with credit that is primarily for personal, household or family purposes. The Risk-Based Pricing Rules take effect January 1, 2011. THE ROUTEONE SOLUTION RouteOne will exercise the credit score disclosure exception to the Risk Based Pricing notice requirement that will give the dealer the ability to print a credit score disclosure notice (‘Credit Score Disclosure Notice’) for all of the dealers’ consumers that require a risk-based pricing notice under the Risk-Based Pricing Rule. The Credit Score Disclosure Notice must be delivered to consumers as soon as reasonably practicable after the credit score has been obtained, but in any event at or before consummation of the financing transaction; this is before the consumer signs the retail installment sales contract. Under the credit score disclosure exception, all consumers that request an extension of credit must receive the Credit Score Disclosure Notice. If the related credit report was pulled from within RouteOne, the Credit Score Disclosure Notice will be generated automatically upon dealer request, and will be automatically populated with the credit score* (scores will be populated from TransUnion, Experian or Equifax, depending on which bureau the dealer utilizes to obtain scores) and all consumer information, including consumer street address, city, state, and zip code. The dealer may also generate a Credit Score Disclosure Notice even if the credit report was pulled outside of RouteOne; the Credit Score Disclosure Notice will be automatically populated with all consumer information, including consumer street address, city, state, and zip code; however the dealer will be provided with a pop-up window in which to manually input the credit score, score date and credit bureau name. The solution is FREE, and will be available December 2010. DIRECT LENDING STATES RouteOne accommodates the generation of the Credit Score Disclosure Notice on behalf of finance sources that engage in direct lending through dealership agents (this feature is available in Arkansas and Ohio). The Credit Score Disclosure Notice that is generated will identify the dealer providing the notice on behalf of the finance source granting credit. The RouteOne user interface will present the dealer with a mandatory dialog ‘check box’ requiring the dealer user to assert that the required risk-based pricing notice (in this case the Credit Score Disclosure Notice) will be presented to the consumer. PRODUCT BENEFITS • Dealers may print a Credit Score Disclosure Notice for every customer that requests an extension of credit (saving dealers time deciding which customers require a notice) • Notices will be generated for the following: 1. Dealers pulling bureaus within RouteOne (credit score and consumer information will be automatically populated) 2. Dealers pulling bureaus outside of RouteOne (consumer information will be automatically populated and the system will invoke a pop-up window for dealer to enter the credit score information necessary to create the notice) 3. Consumers with no credit • Notices will be included in the Deal Manager, Compliance Manager, and Deal Summary, allowing dealerships to archive all of their compliance activities within RouteOne • Dealers may print the Credit Score Disclosure Notice after pulling a credit bureau score and track whether or not notices have been printed • All notices can be archived to RouteOne’s SecureDocOne document storage tool (provided dealer is a subscriber) • Product is FREE to dealerships *The RouteOne solution will automatically populate the Credit Score Disclosure Notice with the following credit scores: Experian/FICO® Risk Model v2 - Auto Loan Model, TransUnion FICO Auto 04 and All Equifax score models. Please contact your captive representative, your RouteOne Business Development Manager, or RouteOne Sales Support at 866.933.0663 for additional information. www.routeone.com © 2010 RouteOne LLC (12/10)
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