Comment submitted by HSBC Finance Corporation

VIA ELECTRONIC MAIL August 18, 2008 Jennifer J. Johnson, Secretary Federal Trade Commission Board of Governors of the Federal Reserve Office of the SecretarySystem Room H-135 (Annex M) th20 Street and Constitution Avenue, NW 600 Pennsylvania Avenue, NW Washington, DC 20551 Washington, DC 20580 Attention: Docket No. R-1316 Attention: Project No. R411009 regs.comments@federalreserve.gov https://secure.commentworks.com/ ftc-RiskBasedPricing Re: FACT Act Risk-Based Pricing Rule, Docket No. R-1316 Project No. R411009 Ladies and Gentlemen: 1In response to the notice of proposed rulemaking, HSBC Finance Corporation , and HSBC Bank USA, N.A., (collectively “HSBC”), are pleased to comment on the proposed rules to implement the risk-based pricing provisions of section 311 of the Fair and Accurate Credit Transactions Act of 2003 (“FACT Act”). HSBC’s affiliated companies worldwide serve over 125 million customers and comprise one of the largest financial services organizations in the world. In the United States and Canada, HSBC businesses provide financial products to nearly 60 million customers. With such a broad and expansive customer base, HSBC is a significant user of credit reports. Section 311 of the FACT Act adds a new section 615(h) to the Fair Credit Reporting Act (“FCRA”). Section 616(h) requires creditors to provide a risk-based pricing notice to consumers when the creditor uses a consumer report in connection with an ...