Exception Rate Justification Form??? damn cfpb. Like most of you, over the past 6 months we've received many CYA letters from our lenders stating that they do not condone or permit discrimination practices within there lending nor do they expect their dealers to. This is being done in the wake of all the CFPB mumbo jumbo, obviously. We were also encouraged by our garage insurance company (Zurich) to instate an "Exception Rate Justification Form". An internal form that is meant to justify why you gave customer X a higher/lower rate as opposed to giving them any other rate that you would typically give. Sounds a little silly to me. Has anyone else instituted this form in their operations?