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information by common ownership or control, Section 615(b) (2) requires the user to notify the consumer of the adverse action. <br />The notice must inform the consumer that he or she may obtain a disclosure of the nature of the information relied upon by <br />making a written request within 60 days of receiving the adverse action notice. If the consumer makes such a request, the user <br />must disclose the nature of the information not later than 30 days after receiving the request. If consumer report information is <br />shared among affiliates and then used for an adverse action, the user must make an adverse action disclosure as set forth in <br />I.C.1 above. <br />D. Users Have Obligations When Fraud and Active Duty Military Alerts are in Files <br />When a consumer has placed a fraud alert, including one relating to identify theft, or an active duty military alert with a <br />nationwide consumer reporting agency as defined in Section 603(p) and resellers, Section 605A (h) imposes limitations on <br />users of reports obtained from the consumer reporting agency in certain circumstances, including the establishment of a new <br />credit plan and the issuance of additional credit cards. For initial fraud alerts and active duty alerts, the user must have <br />reasonable policies and procedures in place to form a belief that the user knows the identity of the applicant or contact the <br />consumer at a telephone number specified by the consumer; in the case of extended fraud alerts, the user must contact the <br />consumer in accordance with the contact information provided in the consumer’s alert. <br />E. Users Have Obligations When Notified of an Address Discrepancy <br />Section 605(h) requires nationwide CRAs, as defined in Section 603(p), to notify users that request reports when the address <br />for a consumer provided by the user in requesting the report is substantially different from the addresses in the consumer’s file. <br />When this occurs, users must comply with regulations specifying the procedures to be followed. <br />Federal regulations are available at www.consumerfinance.gov/learnmore. <br />F. Users Have Obligations When Disposing of Records <br />Section 628 requires that all users of consumer report information have in place procedures to properly dispose of records <br />containing this information. Federal regulations are available at www.consumerfinance.gov/learnmore. <br />II. CREDITORS MUST MAKE ADDITIONAL DISCLOSURES <br />If a person uses a consumer report in connection with an application for, or a grant, extension, or provision of, credit to a <br />consumer on material terms that are materially less favorable than the most favorable terms available to a substantial proportion <br />of consumers from or through that person, based in whole or in part on a consumer report, the person must provide a risk-based <br />pricing notice to the consumer in accordance with regulations prescribed by the CFPB. Section 609(g) requires a disclosure by <br />all persons that make or arrange loans secured by residential real property (one to four units) and that use credit scores. These <br />persons must provide credit scores and other information about credit scores to applicants, including the disclosure set forth in <br />Section 609(g) (1) (D) (“Notice to the Home Loan Applicant”). <br />III. OBLIGATIONS OF USERS WHEN CONSUMER REPORTS ARE OBTAINED FOR EMPLOYMENT <br />PURPOSES <br />A. Employment Other Than in the Trucking Industry <br />If the information from a CRA is used for employment purposes, the user has specific duties, which are set forth in Section <br />604(b) of the FCRA. The user must: <br />An adverse action notice also is required in employment situations if credit information (other than transactions and experience <br />data) obtained from an affiliate is used to deny employment. Section 615(b) (2). The procedures for investigative consumer <br />reports and employee misconduct investigations are set forth below. <br />DocuSign Envelope ID: ED55B3D5-BAD0-45B4-977B-F09C4091C16A