It's not too early to begin preparing for the operational changes called for by the new risk-based pricing regulations under the Fair Credit Reporting Act (FCRA) that become effective January 1, 2011.  The new regulations require that, among other things, lenders provide notice to consumers whenever a credit report is used in making a credit decision when the credit is granted on "material terms that are materially less favorable than the most favorable terms available to a substantial proportion of consumers."  If that requirement is less than crystal clear to you, I refer you to an excellent article co-written by Andrew Smith and Joe Gabai, attorneys at the law firm of Morrison & Foerster, entitled "Compliance with the New Risk-Based Pricing Rule."  The article is available online here.  The article includes links to the final rule in the article as well as copies of the model notices.