The requirment to send a risk-based pricing notice to consumers, published as 16 CFR 640, only applies to offers for credit or insurance that are made based in part on a consumer report obtained from a credit reporting agency.
Internal records of a creditor is not informaiton obtained from a consumer reporting agency, and thus does not trigger requirment for a notice of risk-based pricing.
FCRA 603(2) explicitly excludes a report based only on internal information retained by a creditor as being a consumer report within the meaning of the FCRA.
"16 CFR §640.3 General requirements for risk-based pricing notices.
(a) In general. Except as otherwise provided in this part, a person must provide to a consumer a notice (“risk-based pricing notice”) in the form and manner required by this part if the person both—
(1) Uses a consumer report in connection with an application for, or a grant, extension, or other provision of, credit to that consumer that is primarily for personal, family, or household purposes; and
(2) Based in whole or in part on the consumer report, grants, extends, or otherwise provides credit to that consumer on material terms that are materially less favorable than the most favorable material terms available to a substantial proportion of consumers from or through that person."
