No, we are not aware of any requirement for customers to sign the risk-based pricing notice or for a copy of the notice to be retained by your bank. We are aware that some banks do have a policy that requires customer signatures on the notices, along with a document retention policy for retaining such notices, as these practices could assist in demonstrating compliance with the risk-based pricing notice requirement. However, we also should note there are different perspectives on whether to follow these practices. Some banks intentionally do not require and retain signed notices in order to avoid potential problems with having loan files that do not include a signed notice in violation of a bank policy.

For resources related to our guidance, please see below:

• 12 CFR 1022.73(b) (form requirements for the risk-based notice)