FCRA & CRA Compliance

1. Permissible purpose categories

An HOD Report that is a consumer report may be furnished only for one of the permissible purposes enumerated in 15 U.S.C. § 1681b, including:

• Written instructions of the consumer to whom the report relates.
• Extension of credit, review, or collection of an account of the consumer.
• Employment purposes, subject to separate written disclosure and authorization under 15 U.S.C. § 1681b(b).
• Underwriting of insurance involving the consumer.
• Determination of eligibility for a license or benefit granted by a governmental instrumentality required by law to consider financial responsibility.
• Legitimate business need in connection with a business transaction initiated by the consumer, or to review an account to determine whether the consumer continues to meet the terms of the account.
• Court orders or federal grand jury subpoenas.

2. User certification

Every user requesting an HOD Report for a consumer reporting purpose must, prior to access and prior to each renewal, provide a written certification identifying (i) the specific permissible purpose, (ii) the consumer to whom the report relates, (iii) the intended use, (iv) compliance with all federal, state, and local laws applicable to that use, and (v) that the report will not be used for any other purpose. Certifications are logged with a timestamp, IP address, and account identifier and are retained as part of the audit trail.

3. Employment reports

If you intend to use an HOD Report for employment purposes, you must (a) make a clear and conspicuous written disclosure to the consumer in a document consisting solely of the disclosure, (b) obtain the consumer’s written authorization, (c) before taking any adverse action based in whole or in part on the report, provide the consumer with a copy of the report and a copy of “A Summary of Your Rights Under the Fair Credit Reporting Act” issued by the Consumer Financial Protection Bureau, and (d) after taking adverse action, provide notice as described in Section 5. Additional state and local requirements (including “ban the box,” fair-chance laws, and pay-inquiry laws) may apply and are your responsibility to satisfy.

4. Investigative consumer reports

If your use meets the definition of an “investigative consumer report” under 15 U.S.C. § 1681a(e), you must provide the consumer with the disclosure required by 15 U.S.C. § 1681d and honor requests for the nature and scope of the investigation.

5. Adverse action notice obligations

Any person who takes an adverse action against a consumer based in whole or in part on an HOD Report obtained for a permissible purpose must provide the consumer with (i) notice of the adverse action, (ii) the name, address, and toll-free telephone number of Hub or Dub, (iii) a statement that Hub or Dub did not make the decision and cannot provide the specific reasons for it, and (iv) notice of the consumer’s right to obtain a free file disclosure from Hub or Dub within sixty (60) days and to dispute the accuracy or completeness of the information, all in accordance with 15 U.S.C. § 1681m. Additional risk-based pricing notices may be required under 15 U.S.C. § 1681m(h).

6. Consumer rights honored by Hub or Dub

• Free file disclosure once every twelve months and in the circumstances required by 15 U.S.C. § 1681j.
• Dispute and reinvestigation under 15 U.S.C. § 1681i, completed within thirty (30) days (extended by up to fifteen (15) days if you supply additional information during the investigation).
• Correction, deletion, or notation of inaccurate, incomplete, or unverifiable information, with notice to prior recipients on request.
• Security freeze and fraud alert at no cost under 15 U.S.C. § 1681c-1.
• Identity theft block of information resulting from identity theft under 15 U.S.C. § 1681c-2.
• Statutory retention limits under 15 U.S.C. § 1681c (typically seven (7) years for adverse items and ten (10) years for bankruptcies, subject to statutory exceptions).
• State equivalents, including the California Consumer Credit Reporting Agencies Act, the Maine and Massachusetts Fair Credit Reporting Acts, the New York Fair Credit Reporting Act, and comparable statutes.

7. Data categories and how they are treated

Hub or Dub separates the information it holds into distinct categories, each with different handling, verification, display, and legal treatment:

• Consumer report information. Information bearing on a consumer’s credit worthiness, credit standing, character, general reputation, personal characteristics, or mode of living that is used or expected to be used for an FCRA-covered eligibility purpose. Furnished only to verified HOD Pro+ and HOD Enterprise+ business accounts with a certified permissible purpose recorded for each request, and always subject to the full FCRA framework described on this page.
• Reputation information (HOD Score). Verified findings, corroborated documentation, and investigator determinations expressed as a 0 to 1,000 HOD Score. When a HOD Score or the underlying file is used for an eligibility decision, it is treated as consumer report information.
• Public-record information. Court records, licensing records, registrations, and other lawfully available government records. Public-record items are independently corroborated against the source before publication, are subject to the statutory retention limits in 15 U.S.C. § 1681c, and are re-verified when reported for employment purposes as required by 15 U.S.C. § 1681k.
• User-submitted content (HOD Drops). Information submitted by consumers, businesses, or the public. Submissions are free, are never published as received, and are excluded from any HOD Score or HOD Report unless and until an investigator verifies them against independent documentation. Unverified, anonymous, or speculative submissions are rejected.
• Self-provided identity and account data. Information you supply to verify your identity, claim your file, or operate your account. It is used for verification, security, fraud prevention, and service delivery, and is governed by the Privacy Policy, not by the FCRA disclosure framework.

8. Who may obtain a report; no resale

Free consumer and My HOD+ accounts may access, monitor, and dispute only their own file. Verified individuals on HOD Run+ may run reports for personal research, due diligence, and safety review that are not FCRA-covered eligibility decisions, and are contractually prohibited from using any report for employment, tenancy, credit, insurance, or other eligibility determinations. Verified businesses on HOD Pro+ and HOD Enterprise+ are the only users permitted to obtain consumer reports for FCRA-covered decisions, subject to business verification, written permissible-purpose certification for each run, end-user attestation, and audit. HOD Enterprise+ carries identical FCRA obligations to HOD Pro+; its higher service level affects support and administration only.

No plan, tier, add-on, seat count, service level, or negotiated term sold by Hub or Dub reduces, waives, delays, or circumvents any right afforded to consumers under the Fair Credit Reporting Act (15 U.S.C. § 1681 et seq.), Regulation V (12 C.F.R. Part 1022), or any other applicable federal or territorial law. HOD Enterprise+ is not an exception. Every consumer keeps the same rights to free file disclosure, dispute, reinvestigation, correction, deletion of unverifiable information, notice of adverse action, and a record of who accessed their file, regardless of which plan the requesting party holds or how much that party pays.

Plan access matrix

Hub or Dub is not a reseller as defined in 15 U.S.C. § 1681a(u). We assemble and verify our own file information and do not resell consumer reports assembled by another consumer reporting agency. Users of HOD Reports may not resell, redistribute, sublicense, syndicate, or re-furnish a report or any portion of it to any third party, and may not use a report for any purpose other than the purpose certified at the time of the run.

9. Accuracy procedures and recordkeeping

Hub or Dub follows reasonable procedures to assure maximum possible accuracy under 15 U.S.C. § 1681e(b). Every item is evidence-backed, source-attributed, and reviewed by a human investigator before publication; every active file is re-reviewed at least once every three (3) months; and disputed items are marked, reinvestigated, and corrected, deleted, or annotated based on documentation. We maintain records of every permissible-purpose certification, report run, identity verification, dispute, reinvestigation outcome, correction, and disclosure recipient, retained for the period required by applicable federal and state law and available to consumers and regulators on request.

10. Summary of Your Rights Under the FCRA

The current version of the Summary of Your Rights Under the Fair Credit Reporting Act issued by the Consumer Financial Protection Bureau is available at files.consumerfinance.gov and is included with every adverse action notice, file disclosure, and dispute response we generate. State-specific supplements are provided where required.

11. Regulatory cooperation and audits

Hub or Dub cooperates with the Consumer Financial Protection Bureau, the Federal Trade Commission, state attorneys general, and equivalent regulators nationwide. Business users of HOD Reports agree to reasonable audit rights sufficient to demonstrate ongoing permissible-purpose compliance, on reasonable advance notice and subject to confidentiality.

12. Contact for consumer reporting matters

Hub or Dub Inc., Consumer Relations, consumers@hubordub.com. Free file disclosures, disputes, and adverse action inquiries: hubordub.com/disputes. Consumers may also reach us at help@hubordub.com or through the secure support ticket system. Hub or Dub does not provide telephone support; inquiries are answered within 48 hours.

Hub or Dub Inc.'s National Headquarters is located at 101 6th Avenue, 9th Floor, New York, New York 10013. Hub or Dub Inc. does not currently accept in-person visits to its HQ, and does not accept postal mail, walk-ins, in-person appointments, document drop-offs, or on-site service requests. All inquiries must be submitted online through the appropriate channels provided. All support, verification, reporting, investigations, and disputes are handled remotely through approved digital channels. Please scan and email all documentation to help@hubordub.com.