FCRA credit report

(Policies and Procedures for FCRA Compliance)
Company Name: Novel Energy and JoinSolar.org
Effective Date: 10/1/2024

1. Purpose

The purpose of this document is to establish policies and procedures for handling consumer disputes related to credit information in compliance with the Fair Credit Reporting Act (FCRA). This policy ensures that Novel Energy and JoinSolar.org maintain accurate consumer information and respond promptly to disputes regarding the accuracy or completeness of consumer credit data.

2. Scope

This policy applies to all employees, contractors, and agents of Novel Energy and JoinSolar.org involved in handling consumer credit information, processing disputes, and reporting information to Credit Reporting Agencies (CRAs).

3. Definitions

• Consumer: An individual whose credit information is collected, maintained, and reported to CRAs. Consumers will be informed of the status of their disputes during the investigation process, particularly if additional information is required or the investigation exceeds thirty (30) days.
• Dispute: A formal claim raised by a consumer challenging the accuracy or completeness of the credit information maintained by the company.
• Credit Reporting Agency (CRA): An entity that collects and reports consumer credit information (e.g., Equifax, Experian, TransUnion).
• Furnisher: Novel Energy or JoinSolar.org, acting as a furnisher of consumer credit information to CRAs.

4. FCRA Compliance Responsibilities

4.1 Furnisher Obligations

Novel Energy and JoinSolar.org are required to:

• Provide accurate and complete information to CRAs.
• Investigate consumer disputes regarding the accuracy of information furnished to CRAs.
• Correct or delete inaccurate or incomplete information.
• Notify the CRAs of any corrections or updates.
• Novel Energy and JoinSolar.org must ensure that corrections or deletions to consumer information are reported to the CRA(s) within sixty (60) calendar days from receipt of the dispute, per FCRA guidelines.

4.2 Designation of a Compliance Officer

• A Compliance Officer will be designated to oversee all dispute handling procedures, ensuring that FCRA obligations are met.
• The Compliance Officer will ensure that the company’s policies align with current FCRA regulations.

5. Dispute Submission Process

5.1 Consumer Submission Methods

Consumers may submit disputes regarding their credit information through:

• Mail: Send a written dispute to the designated address [Insert Mailing Address].
• Email: Submit disputes via email to [Insert Email Address].
• Phone: Call our customer service line at [Insert Phone Number] to initiate a dispute.

5.2 Information Required from Consumer

When submitting a dispute, consumers should provide:

• Full name, address, and contact information.
• Description of the inaccurate information.
• Account number(s) in question.
• Supporting documentation
  • Including but not limited to relevant billing statements, prior communication records, account statements, credit reports or any documents that substantiate the consumer’s claim.

6. Internal Investigation Procedure

6.1 Acknowledgment of Dispute

Upon receipt of a dispute, the company must:

• Acknowledge receipt of the dispute within 5 business days.
• Log the dispute in the Dispute Resolution System (DRS).

6.2 Investigation Timeline

• Standard Investigation Period: Investigations must be completed within 30 days of receiving the dispute.
• Extended Period: An additional 15 days may be granted if the consumer provides additional information.

6.3 Investigation Steps

• Review Consumer Information: Review the consumer’s account and identify the disputed information.
• Contact CRA: Notify the CRA(s) of the dispute and request verification of the information.
• Gather Evidence: Collect relevant documentation, including internal records, communications, and third-party verification.
• Evaluate Accuracy: Determine whether the information is accurate, incomplete, or inaccurate based on the evidence.

6.4 Resolution of the Dispute

• Inaccurate Information: If the disputed information is found to be inaccurate or incomplete, the company must:
  • Correct or delete the information.
  • Notify the CRA(s) within 5 business days.
  • Inform the consumer of the correction or deletion.
• Accurate Information: If the information is accurate, the company must:
  • Provide the consumer with a detailed explanation supporting the accuracy.
  • Notify the CRA(s) that the information was verified as accurate.

• All consumer data collected during the dispute resolution process will be handled according to strict data privacy and security standards, ensuring compliance with applicable federal and state laws.

7. Reporting and Recordkeeping

7.1 Notification to Consumer

• The company must notify the consumer of the outcome of the dispute within 5 business days of completing the investigation. This includes:
  • A summary of the investigation findings.
  • Any changes made to the credit information.
  • Consumer rights under the FCRA, including the right to request additional information.

7.2 Record Retention

• All records related to the dispute, investigation, and resolution must be retained for a period of five (5) years from the date of resolution.
• Documentation should be stored in the company’s Dispute Resolution System for auditing and legal purposes.

8. Training and Compliance Audits

8.1 Employee Training

• All employees involved in dispute handling must undergo annual training on FCRA compliance, consumer rights, and dispute investigation procedures.

8.2 Compliance Audits

• Internal audits will be conducted annually to ensure compliance with FCRA requirements.
• Audit findings must be reviewed by the Compliance Officer, and any deficiencies must be corrected within thirty (30) days.

9. Consumer Rights Under FCRA

Consumers have the following rights under the FCRA:

• The right to dispute inaccurate information with CRAs and furnishers.
• The right to obtain free copies of their credit reports under certain circumstances.
• The right to request correction or deletion of inaccurate or incomplete information.

10. Amendments

This policy may be amended to reflect changes in the FCRA or company practices. Any amendments must be approved by the Compliance Officer and communicated to all relevant employees.

11. Contact Information

For any questions regarding this Dispute Investigation Policy or to submit a dispute, consumers may contact:

• Compliance Officer: [Will Haffield]
• Mailing Address: [2302 Wycliff St, Suite 300 | St. Paul, MN 55114]
• Email: [[email protected]]
• Phone: [651-370-1461]