FCRA Administration Program

At End-User’s request, End-user may elect to have CSI administer pre-adverse and adverse action letters. End-user acknowledges that at all times, complying with the adverse action requirements under the FCRA are solely the responsibility of the End-User, regardless of its participation in the FCRA Administrative Program. Based on program enrollment in writing, CSI will manage the administration of sending pre- adverse and adverse action letters to consumers on behalf of End-User based on the following guidelines and in accordance with the FCRA.

FCRA Administration Program End-User Requirements:

  1. End-user must provide an electronic copy of their logo for creation of pre-adverse and adverse action letters.
  2. End-user must notify CSI to request distribution of pre-adverse and adverse action letters to consumer.
  3. End-user must notify CSI to request distribution of adverse action letter after receiving the results of a reinvestigation if End-user still intends to take adverse action against the consumer.
  4. All notifications must be via email at compliance@creativeservices.com.
    • All notifications must include consumer’s (i) Name and Address; and (ii) specific notice of state where consumer resides and state will consumer will be working.

FCRA Administration Program Process:

  1. End-user notifies CSI of pre-adverse action via email at compliance@creativeservices.com
  2. End-user receives email confirmation that request was received and will be processed within three (3) business days.
    • CSI sends consumer (i) Pre-adverse action letter; (ii) Copy of consumer report;
      (iii) FCRA Summary of Rights; and (iv) State Specific Summary of Rights/Notices (if applicable).
  3. CSI sends an electronic copy of pre-adverse action letter to End-user.

If applicant does not dispute information in the consumer report within five (5) business days (unless otherwise required by law), CSI sends consumer: (i) Adverse action letter; (ii) Copy of consumer report; (iii) FCRA Summary of Rights; and (iv) State Specific Summary of Rights/Notices (if applicable).

If applicant disputes information in the consumer report, CSI’s Compliance Department will notify End-user of dispute, process reinvestigation, and deliver results of reinvestigation to End-user and consumer.

  • After reviewing reinvestigation results, End-user must notify CSI if End-user still intends to take adverse action and to request distribution of adverse action letter;
  • CSI sends an electronic copy of adverse action letter to End-user;
  • CSI retains copies of all letters in consumer’s file; and
  • CSI maintains an electronic log of all FCRA actions.