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July 08, 2011

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Dianna

If we are able to construct our form into a one page document that includes all required information, will we still be covered by safe harbor?
Thank you for all your time putting together these simplified guidelines so quickly!

Steve Van Beek

Dianna,
I'm not sure how the CU would be able to get the disclosure down to one page. Appendix H to Reg V (Part 222) has the acceptable changes and modifications to the risk-based pricing notices. It also lists two unacceptable changes - including "ii. Eliminating empty lines and extra spaces between sentences within the same section."

You would have to review the allowed modifications in Appendix H in order to determine if your notice would retain the safe harbor.

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