Everybody knows that the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Act"), which was passed by Congress July 21, 2010, greatly impacts banks and other financial institutions. But few thought it may affect utilities and telecommunications companies as well - until now, that is. The issue: disclosure of credit scores.

Section 1100F of the Act amends Section 615(h) of the Fair Credit Reporting Act ("FCRA") and is a self-executing provision that becomes effective July 21, 2011. On July 7, 2011, the Federal Reserve Board and the Federal Trade Commission ("FTC"), issued a final rule implementing Section 1100F (the "Rule").

Existing Section 615(h) of FCRA requires a person to provide a "risk-based pricing notice" to a consumer when the person uses a consumer report in connection with an extension of credit and, based in whole or in part on the consumer report, extends credit to the consumer on terms that are materially less favorable than the most favorable terms available to a substantial proportion of consumers.

For the first time, as a result of the adoption of Section 1100F, persons who issue risk-based pricing notices must include the applicant's credit score in the notice. This new requirement has significant implications for businesses that are subject to it.

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