The recognized purposes
The Fair Credit Reporting Act enumerates the situations in which a consumer report may be furnished. The common ones cover credit transactions, employment purposes, tenant screening, insurance underwriting, account review, certain business transactions initiated by the consumer, and specific legitimate business needs.
Personal curiosity, monitoring an ex-partner, investigating a neighbor, and researching an opposing party outside a recognized purpose are not on the list.
- Credit transactions involving the consumer.
- Employment purposes, with the required disclosures.
- Tenant screening for a rental application.
- Insurance underwriting.
- Account review of an existing relationship.
- A business transaction the consumer initiated.
Certification is not a checkbox
A user of consumer reports certifies the specific purpose of each request and agrees not to use the report for any other purpose. That certification is the record an examiner or a court reads later.
It should therefore be recorded per run, with the actor, the timestamp, and the jurisdiction, not signed once at account opening and forgotten.
How Hub or Dub enforces it
Running a report on another person or business requires an eligible subscription and a certified purpose captured at the moment of the run. Every pull is logged permanently with actor, purpose, IP, and jurisdiction.
Free consumer accounts and My HOD+ accounts can view, monitor, and dispute their own file only. They cannot run reports on anyone else, by design.
