Required FCRA Notices and Compliance Practices

1. A Summary of Your Rights Under the Fair Credit Reporting Act

Every consumer receives the CFPB's prescribed Summary of Consumer Rights (12 C.F.R. Part 1022, Appendix K) with each file disclosure. It is also published at Your Rights. You have the right to know what is in your file, to receive a free disclosure, to dispute incomplete or inaccurate information, to have unverifiable information corrected or deleted, to limit access to your file to those with a permissible purpose, to consent before reports are provided to employers, to limit prescreened offers, to seek damages from violators, and additional rights as an identity theft victim or active duty military consumer.

2. Remedying the Effects of Identity Theft

Consumers who believe they are victims of identity theft receive the CFPB's prescribed Summary of Rights of Identity Theft Victims (Appendix I). Hub or Dub will, on request with appropriate proof of identity and an identity theft report, block information resulting from identity theft within four business days under 15 U.S.C. § 1681c-2, notify the furnisher of the block, and provide the consumer with information on fraud alerts, active duty alerts, and security freezes available through the nationwide consumer reporting agencies. Hub or Dub refers fraud alert requests to the nationwide agencies as required by 15 U.S.C. § 1681c-1.

3. Notice to Users of Consumer Reports: Obligations of Users Under the FCRA

Every business permitted to obtain an HOD Report receives the CFPB's prescribed Notice to Users (Appendix N) before access is granted and must acknowledge it. Users must:

• Obtain reports only for a permissible purpose under 15 U.S.C. § 1681b and certify that purpose for each report.
• For employment purposes, provide a clear and conspicuous standalone disclosure, obtain written authorization, certify compliance, and provide a pre-adverse action notice with a copy of the report and the Summary of Rights before taking adverse action.
• Provide an adverse action notice under 15 U.S.C. § 1681m identifying Hub or Dub, its contact details, a statement that Hub or Dub did not make the decision, and the consumer's right to a free copy within 60 days and to dispute.
• Follow address discrepancy, identity theft red flag, and record disposal requirements, and never use or redisclose report information for any other purpose.
• Obtain additional disclosures and consent before procuring an investigative consumer report under 15 U.S.C. § 1681d, and not obtain medical information except as permitted under 15 U.S.C. § 1681b(g).

4. Notice to Furnishers of Information

Every person who furnishes information to Hub or Dub receives the CFPB's prescribed Notice to Furnishers (Appendix M). Furnishers must not report information they know or have reasonable cause to believe is inaccurate, must promptly correct and update information, must note when information is disputed by the consumer, must investigate disputes forwarded by Hub or Dub within the statutory period, must report the date of delinquency, and must maintain reasonable written policies regarding accuracy and integrity under 12 C.F.R. § 1022.42.

5. Compliance practices Hub or Dub maintains

• Maximum possible accuracy. Reasonable procedures under 15 U.S.C. § 1681e(b), including human Back Office verification before any information affects an HOD Score or Report.
• User verification. Identity verification of every prospective user and certification of permissible purpose under 15 U.S.C. § 1681e(a).
• Free file disclosures. Consumers may access their own file and HOD Score free at any time, with the sources of information and a record of each person who procured a report, under 15 U.S.C. § 1681g.
• Disputes. Free reinvestigation completed within 30 days (45 days when the consumer supplies additional information during the period), notice to the furnisher within five business days, written results within five business days of completion, and deletion of information that cannot be verified, under 15 U.S.C. § 1681i.
• Obsolete information. Adverse items are excluded after the periods set by 15 U.S.C. § 1681c, including seven years for most adverse information and ten years for bankruptcies, subject to statutory exceptions.
• Public record information for employment. Notice to the consumer or strict procedures to keep public record information complete and up to date under 15 U.S.C. § 1681k.
• Medical information. Medical information is not furnished except as permitted under 15 U.S.C. § 1681b(g), and medical furnisher names are coded.
• Security and disposal. Safeguards under the Gramm-Leach-Bliley Act Safeguards Rule and secure disposal of consumer report information under 16 C.F.R. Part 682.
• Prescreening. Hub or Dub does not furnish prescreened lists.
• State law. Hub or Dub also complies with applicable state consumer reporting laws, which may provide additional rights. State notices are listed at U.S. State Privacy Rights.

6. Contact

To request your file, file a dispute, or report identity theft, use your account or email hello@hubordub.com. You may also contact the Consumer Financial Protection Bureau at consumerfinance.gov. The official text of each prescribed notice is available from the CFPB at consumerfinance.gov.

This page summarizes legal obligations and is reviewed periodically. It does not replace the prescribed CFPB forms, which control in the event of any difference.