Anthony LaFaziaCEO, Atlantic Training · CEO at Atlantic Training | EdTech & Safety Compliance Leader

FCRA Risk-Based Pricing Rule Explained: Account Reviews, APR Increases & Credit Score Disclosures

25 Jun 2026 · 1 min

Watch on YouTube

0:48

In this segment of a compliance‑focused YouTube video, the presenter explains the Fair Credit Reporting Act (FCRA) risk‑based pricing rule as it applies to routine account reviews. When a lender’s automated or manual credit check shows a significant drop in a consumer’s credit score and the lender decides to raise the APR, the law requires a risk‑based pricing notice. The speaker details the timing requirement—either at the moment the APR increase is communicated or, if omitted, no later than five days after the rate becomes effective. He warns that automated pricing systems often overlook the notice step, creating a compliance risk. The segment also contains a brief promotional read for Atlantic Training’s WAVE HR/training platform.

Chapters

Now I want to pivot to a specific scenario that trips people up a lot: account reviews. Say you have a longtime customer. You do a routine checkup on their credit and yikes, their score, it dropped like a stone. So you decide to raise their APR to match that new risk. Can you do that? Sure. But if you increase an APR based on a consumer report, you must provide a risk-based pricing notice.
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The timing here is tight. You have to provide the notice either at the time you communicate the APR increase decision to the consumer, or if no notice is provided before the rate goes into effect, no later than 5 days after the effective date of the change. They need to know why their rate went up. This is a huge gotcha because automated systems sometimes miss this step. If your system automatically adjusts rates based on risk scores, make sure it's also automatically spitting out that notice. Otherwise, you're non-compliant.