Kim,
I’ve posted below a portion from Reg V (222.70(a)(1) that I think answers your question.
§ 222.70 Scope
(a) Coverage. (1) In general. This subpart applies to any person that both—
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(i) Uses a consumer report in connection with an application for, or a grant,
extension, or other provision of, credit to a consumer that is primarily for personal,
family, or household purposes; and
(ii) Based in whole or in part on the consumer report, grants, extends, or
otherwise provides credit to the 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.
The regulation doesn’t mention anything about the freshness, if you will, of the report relied upon. I do believe you would need to apply which ever option you are using to address the Risked-Based Pricing Notice requirement.