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Gm520 Homework Week 2

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Week 2 Homework – GM520.

By Sam Jhonson

1. The Federal Trade Commission and the Federal Reserve Board was seeking amendments to the Risk-Based Pricing Rule that would require creditors, as of July 21, 2011. I am starting my own business so this interests me as to how the credit scores are reported to the consumers.

2. The proposal makes the creditors to disclose the credit score information to the consumers when a credit score is used in setting or adjusting credit terms. Also consumers who receive the notice can obtain a free credit report to check the report’s accuracy. As an alternative to providing the notice, the Rule permits creditors to provide credit applicants with a free credit score and information about their score.

3. The agencies should provide additional information related to credit scores to the risk-based pricing notices. Specifically, the risk-based pricing notice include an explanation that the consumer does not have a single credit score, and that the credit score may vary with the consumer reporting agency and a particular credit product for which the consumer applied. Most consumers need this information to help them understand why they are receiving a particular score that may not be the same as a FICO score.

4. All the comments must be received by 04/14/10 and comments on he Paperwork Reduction Act analysis set forth in Section III.A. of this Federal Register notice must be received on or before May 16, 2011.

5. a. 1. Go to the Hearing for the proposed rule. 2. Public comments after modification. 3. If not satisfied, challenge the rule in court.

b. If the proposal passes, identify and explain the five legal theories you could use in an attempt to have the regulation declared invalid and overturned in court.

(will provide after homework due)

c. Which of these challenges would be the best way to challenge the

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