1.1 Policy Purpose

• To establish standardized procedures for receiving, processing, investigating, and responding to consumer disputes regarding credit information furnished by HL Hunt to consumer reporting agencies.
• To ensure full compliance with the Fair Credit Reporting Act (FCRA) § 1681s-2(b), which establishes furnisher duties upon notice of dispute, and all related regulations.
• To define roles, responsibilities, and accountability structures for all personnel involved in dispute handling operations.
• To protect consumer rights by ensuring accurate reporting and thorough investigation of disputed information.
• To minimize regulatory, legal, and reputational risk through robust compliance controls and governance structures.
• To maintain the accuracy and integrity of all consumer credit information furnished by HL Hunt.

1.2 Scope of Application

• This policy applies to all consumer disputes regarding personal credit accounts and tradelines furnished by HL Hunt to Equifax, Experian, TransUnion, and any specialty consumer reporting agencies.
• Covered disputes include challenges to: account ownership, account status, payment history, balance information, credit limits, dates of activity, personal identifying information, and any other data elements reported by HL Hunt.
• This policy governs disputes received through the ACDV system from CRAs as well as direct disputes received from consumers via mail, email, telephone, or other channels.
• All business units, departments, and affiliated entities that furnish consumer data or participate in dispute handling are subject to these requirements.

1.3 Policy Objectives

• Process all ACDV disputes within the timeframes mandated by the FCRA (generally within 30 days of receipt).
• Conduct thorough and reasonable investigations of all disputed information using all relevant records and documentation.
• Report accurate investigation results to CRAs and update or delete information determined to be inaccurate or unverifiable.
• Maintain comprehensive documentation of all dispute activities for compliance and audit purposes.
• Provide clear communication to consumers regarding their dispute rights and resolution outcomes.

2.1 Regulatory Definitions

• "FCRA" refers to the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq., as amended, including all implementing regulations.
• "Furnisher" refers to HL Hunt in its capacity as an entity that furnishes consumer credit information to consumer reporting agencies, subject to FCRA § 1681s-2.
• "Consumer Reporting Agency (CRA)" refers to Equifax, Experian, TransUnion, and any other entity meeting the definition under FCRA § 1681a(f).
• "ACDV" refers to the Automated Consumer Dispute Verification, the electronic system used by CRAs to transmit dispute notifications and receive furnisher responses.
• "AUD" refers to the Automated Universal Dataform, used to transmit account updates and corrections to CRAs outside the dispute process.
• "CFPB" refers to the Consumer Financial Protection Bureau, the federal agency responsible for FCRA enforcement.

2.2 Dispute-Related Definitions

• "Dispute" refers to a consumer's challenge to the accuracy, completeness, or verifiability of information HL Hunt has furnished to a CRA.
• "Indirect Dispute" refers to a dispute submitted by a consumer to a CRA, which is then forwarded to HL Hunt through the ACDV system.
• "Direct Dispute" refers to a dispute submitted directly to HL Hunt by the consumer, without going through a CRA.
• "Reinvestigation" refers to the investigation conducted by HL Hunt upon receipt of a dispute notification to verify or correct reported information.
• "Frivolous Dispute" refers to a dispute that fails to meet the requirements for investigation under FCRA, including disputes that are substantially similar to previously investigated disputes without new information.

2.3 Account and Data Definitions

• "Tradeline" refers to the credit account record that HL Hunt furnishes to CRAs, including all associated data elements.
• "PII" refers to Personally Identifiable Information, including name, Social Security Number, date of birth, address, and other information identifying a specific consumer.
• "System of Record" refers to HL Hunt's authoritative database(s) containing original account information used to verify disputed data.
• "Supporting Documentation" refers to contracts, applications, payment records, correspondence, and other records used to verify account information during dispute investigation.

3.1 FCRA Furnisher Duties Upon Notice of Dispute

Under FCRA § 1681s-2(b), upon receiving notice of a dispute from a CRA, HL Hunt is required to:

• Conduct a reasonable investigation with respect to the disputed information.
• Review all relevant information provided by the CRA pursuant to FCRA § 1681i(a)(2).
• Report the results of the investigation to the CRA.
• If the investigation reveals that the information is incomplete or inaccurate, report those results to all CRAs to which HL Hunt furnished the information.
• If the disputed information is found to be inaccurate or incomplete or cannot be verified, modify, delete, or permanently block the reporting of that information.

3.2 Investigation Timeframes

• HL Hunt shall complete investigations of ACDV disputes and report results to the CRA within thirty (30) days of receiving the dispute notification.
• If the consumer provides additional relevant information to the CRA during the investigation period, the timeframe may be extended to forty-five (45) days.
• For direct disputes, HL Hunt shall complete investigation within thirty (30) days of receiving a dispute that includes sufficient information to investigate.
• HL Hunt targets internal processing of all disputes within twenty-five (25) days to allow adequate time for CRA transmission and processing.

3.3 CFPB Regulation V Requirements

• HL Hunt maintains written policies and procedures regarding the accuracy and integrity of furnished information as required by 12 CFR § 1022.42.
• HL Hunt has established and implemented reasonable procedures for responding to direct disputes as required by 12 CFR § 1022.43.
• All dispute handling procedures are designed to ensure compliance with the Furnisher Rule and related CFPB guidance.

3.4 State Law Compliance

• HL Hunt complies with all applicable state laws governing credit reporting and dispute resolution, including state-specific timeframe requirements where more stringent than federal law.
• State law requirements are identified and incorporated into dispute handling procedures as applicable.
• The Compliance Department monitors state legislative and regulatory developments affecting furnisher obligations.

4.1 ACDV Dispute Intake

• ACDV dispute notifications are received electronically from CRAs through HL Hunt's e-OSCAR or equivalent processing system.
• All incoming ACDVs shall be logged in the Dispute Management System within one (1) business day of receipt with assignment of unique tracking identifiers.
• ACDVs shall be routed to the Dispute Resolution Team for investigation based on dispute type and complexity.
• System alerts shall notify supervisory personnel of approaching FCRA deadlines to ensure timely processing.
• Daily reports shall be generated showing all pending disputes, days remaining until deadline, and assigned investigators.

4.2 Dispute Categorization

Upon intake, disputes shall be categorized by type to ensure appropriate handling:

• Account Ownership Disputes: Consumer claims they do not own the account or did not authorize the account.
• Account Status Disputes: Consumer disputes the reported status (open, closed, charged-off, etc.).
• "Balance Disputes: Consumer disputes the reported balance, credit limit, or high balance.
• Payment History Disputes: Consumer disputes reported late payments, delinquencies, or payment patterns.
• Personal Information Disputes: Consumer disputes reported name, address, SSN, or other PII.
• Fraud/Identity Theft Disputes: Consumer claims account resulted from identity theft or fraud.
• Date-Related Disputes: Consumer disputes account open date, close date, or date of first delinquency.
• Duplicate Account Disputes: Consumer claims account is reported multiple times.

4.3 Priority Handling

• Fraud and identity theft disputes shall receive priority handling and be assigned to senior investigators.
• Disputes approaching FCRA deadline (within 5 days) shall be escalated for expedited processing.
• Disputes involving regulatory complaints, legal matters, or executive escalations shall receive priority handling.
• Standard disputes shall be processed in the order received, subject to priority classifications.

5.1 ACDV Response Requirements

• HL Hunt shall respond to all ACDVs prior to the FCRA due date, targeting response submission at least three (3) business days before the deadline.
• Responses shall accurately reflect the results of HL Hunt's investigation using appropriate Metro 2 response codes.
• If information is verified as accurate, the response shall indicate verification with supporting rationale documented internally.
• If information is found to be inaccurate or unverifiable, the response shall indicate the appropriate correction, deletion, or update.
• All ACDV responses shall be reviewed by a supervisor or quality assurance personnel before submission for disputes involving account deletion or significant modifications.

5.2 Response Code Usage

ACDV responses shall utilize appropriate response codes in accordance with e-OSCAR and Metro 2 specifications:

• Verified as Reported: Investigation confirms the disputed information is accurate as currently reported.
• Updated: Investigation revealed information was partially inaccurate; corrections have been made and reported.
• Deleted: Investigation determined information should be removed from consumer's credit file.
• Information Belongs to Another Consumer: Investigation confirmed the account belongs to a different individual.
• Account Closed at Consumer's Request: Account status updated to reflect consumer-initiated closure.
• Paid/Closed: Account updated to reflect paid or closed status.

5.3 Response Documentation

• All ACDV responses shall be documented in the consumer's dispute file with the response code used, rationale for the determination, and supporting evidence reviewed.
• Screen captures or system logs of submitted responses shall be retained for compliance records.
• Response submission confirmations from e-OSCAR shall be retained as proof of timely response.
• Any technical issues preventing timely response shall be documented and escalated immediately.

5.4 Multi-Bureau Updates

• If investigation reveals that disputed information is inaccurate or incomplete, HL Hunt shall report corrections to ALL CRAs to which the information was previously furnished, not just the CRA that forwarded the dispute.
• Multi-bureau updates shall be submitted via AUD or regular reporting cycle within five (5) business days of investigation completion.
• Documentation shall confirm that all applicable CRAs received corrected information.

6.1 Direct Dispute Requirements

Under 12 CFR § 1022.43, HL Hunt must investigate direct disputes that:

• Identify the specific account or information being disputed.
• Explain the basis for the dispute (why the consumer believes the information is inaccurate).
• Include sufficient information to identify the consumer (name, address, and account number or other identifying information).

6.2 Direct Dispute Intake Channels

• Mail: HL Hunt Dispute Resolution, 6844 Bardstown Road, Louisville, KY 40291
• Email: disputes@hlhunt.com
• Online Portal: www.hlhunt.org/disputes
• Telephone: Verbal disputes shall be documented and the consumer shall be advised to submit in writing for optimal processing.

6.3 Direct Dispute Processing

• Direct disputes meeting the requirements for investigation shall be logged in the Dispute Management System within two (2) business days of receipt.
• Acknowledgment of receipt shall be sent to the consumer within five (5) business days.
• Investigation shall be completed within thirty (30) days of receiving a complete dispute.
• If the dispute is incomplete, HL Hunt shall notify the consumer of the additional information needed within five (5) business days.
• Written notification of investigation results shall be sent to the consumer within five (5) business days of completing the investigation.

6.4 Frivolous Direct Disputes

• HL Hunt may determine that a direct dispute is frivolous or irrelevant if it: fails to identify the disputed information, fails to explain the basis for the dispute, is substantially similar to a previously investigated dispute without new information, or is submitted through an improper channel designed to harass.
• If a direct dispute is determined to be frivolous, HL Hunt shall notify the consumer within five (5) business days, including the reasons for the determination and what information would be required to investigate.
• Frivolous dispute determinations shall be made by designated compliance personnel and documented with specific rationale.

7.1 Investigation Standards

• All disputes shall be investigated thoroughly by reviewing all relevant information in HL Hunt's possession, including original account documentation, payment records, correspondence, and system of record data.
• Investigators shall review all relevant information provided by the CRA with the dispute notification, including consumer statements and supporting documentation.
• Investigation shall not be limited to a cursory review of computerized records; original documentation shall be examined when necessary to resolve the dispute.
• The investigation must be reasonable under the circumstances, considering the nature of the dispute and the information available.

7.2 Verification Sources

Investigators shall consult the following sources as applicable to verify disputed information:

• System of Record: HL Hunt's primary database containing authoritative account information.
• Original Account Documentation: Signed applications, contracts, agreements, and enrollment forms.
• Payment Records: Payment history, transaction logs, and remittance records.
• Correspondence Files: Letters, emails, and other communications with the consumer.
• Call Recordings: Recorded telephone conversations with the consumer, where available.
• Identity Verification Records: Documentation used to verify consumer identity at account opening.
• Third-Party Records: Information from collection agencies, credit bureaus, or other sources as applicable.

7.3 Account Ownership Verification

• For disputes challenging account ownership, investigators shall verify the consumer's identity against original account documentation.
• Verification shall include comparison of name, SSN, date of birth, and address on the dispute against account records.
• If account documentation contains a signature, it may be compared against known consumer signatures when feasible.
• If ownership cannot be verified through available documentation, the account shall be deleted from the consumer's credit file.

7.4 Payment History Verification

• For disputes challenging payment history, investigators shall review complete payment records and transaction history.
• Payment posting dates, amounts, and application shall be verified against system records.
• Any discrepancies between reported payment history and actual records shall be corrected.
• If payment records are incomplete or unavailable, the disputed payment history shall be updated to reflect only verifiable information.

7.5 Investigation Documentation

• All investigation activities shall be documented in the consumer's dispute file, including: sources reviewed, findings from each source, rationale for the determination, and evidence supporting the conclusion.
• Documentation shall be sufficient to demonstrate that a reasonable investigation was conducted.
• Investigation notes shall be contemporaneous and created during or immediately following the investigation.

8.1 PII Validation Procedures

• Upon receipt of any dispute, HL Hunt shall validate the consumer's personally identifiable information against account records to confirm the dispute pertains to the correct account and consumer.
• Validation shall include comparison of: full legal name, Social Security Number (full or last four digits), date of birth, and current and historical addresses.
• If PII on the dispute does not match account records, additional verification steps shall be taken before proceeding with investigation.
• PII discrepancies shall be documented and may indicate potential mixed file or identity theft issues requiring special handling.

8.2 Mixed File Identification

• If PII validation suggests the disputed account may belong to a different consumer (mixed file), investigators shall conduct enhanced review to determine correct ownership.
• Mixed file situations shall be escalated to senior investigators for determination.
• If HL Hunt determines that account information was reported to the wrong consumer's file, immediate correction shall be submitted to all CRAs.

8.3 Identity Theft Indicators

• PII validation shall include review for identity theft indicators, including: mismatched SSNs, addresses in different geographic regions, multiple consumers associated with the same SSN, and fraud alerts on file.
• If identity theft is suspected, the dispute shall be routed to the Fraud and Identity Theft team for specialized handling under Section 15.

9.1 Required Documentation

• Complete records of all disputes shall be maintained, including: the original dispute notification (ACDV or direct), all information provided by the CRA or consumer, investigation notes and findings, evidence reviewed, determination rationale, response submitted, and any follow-up communications.
• Documentation shall be sufficient to demonstrate compliance with FCRA investigation requirements.
• Records shall be organized to permit efficient retrieval for regulatory examination, audit, and litigation purposes.

9.2 Retention Periods

• Dispute records shall be retained for a minimum of seven (7) years from the date of dispute resolution.
• Records subject to litigation hold shall be retained until the hold is released, regardless of standard retention periods.
• State law requirements mandating longer retention periods shall be followed where applicable.
• Electronic records shall be maintained in a format that preserves integrity and permits accurate reproduction.

9.3 Record Security

• Dispute records containing consumer PII shall be stored securely with access limited to authorized personnel.
• Electronic records shall be protected by appropriate access controls, encryption, and audit logging.
• Physical records shall be stored in secure facilities with controlled access.
• Record destruction shall be conducted securely in accordance with HL Hunt's data destruction policy.

10.1 Correction Procedures

• When investigation determines that disputed information is inaccurate or incomplete, HL Hunt shall promptly update the information with all CRAs to which it was previously furnished.
• Corrections shall be submitted via ACDV response for the disputing CRA and via AUD or regular reporting for other CRAs.
• All corrections shall be processed within five (5) business days of investigation completion.
• Confirmation of correction submission shall be documented in the dispute file.

10.2 Deletion Procedures

• When investigation determines that disputed information should be deleted (account not owned by consumer, fraud, cannot verify, etc.), HL Hunt shall submit deletion requests to all CRAs.
• Deletions shall be submitted with appropriate codes indicating the reason for deletion.
• HL Hunt shall verify that deletions have been processed by reviewing subsequent credit reports or CRA confirmations when available.

10.3 Preventing Re-Reporting of Deleted Information

• Once information has been deleted as a result of dispute investigation, HL Hunt shall implement controls to prevent re-reporting of the deleted information.
• System flags shall be placed on accounts to suppress future reporting where deletion was due to fraud, identity theft, or account ownership issues.
• Regular reporting processes shall be monitored to ensure deleted information is not inadvertently re-furnished.

10.4 Consumer Notification

• For direct disputes, HL Hunt shall notify the consumer in writing of the investigation results within five (5) business days of completion.
• Notification shall include: the determination made, any changes to the consumer's information, and instructions for obtaining updated credit reports.
• If the dispute was verified as accurate, the notification shall explain the basis for the determination.

11.1 Initial Training Requirements

• All employees assigned to dispute handling roles shall complete comprehensive initial training before processing disputes independently.
• Initial training curriculum shall include: FCRA furnisher obligations under § 1681s-2, CFPB Regulation V requirements, e-OSCAR and ACDV processing, Metro 2 format and response codes, investigation procedures and documentation standards, and consumer information security.
• Training shall include practical exercises using sample disputes and assessments to verify comprehension.
• Training completion shall be documented with certification required before system access is granted.

11.2 Annual Recertification

• All dispute handling personnel shall complete annual recertification training to maintain current knowledge.
• Recertification shall address regulatory updates, policy changes, lessons learned from audits, and common errors identified through quality assurance.
• Employees failing to complete recertification shall be suspended from dispute handling duties until training is completed.

11.3 Specialized Training

• Senior investigators shall receive advanced training on complex disputes, fraud investigation, and regulatory interface.
• Supervisory personnel shall receive training on quality assurance, compliance monitoring, and escalation procedures.
• All employees shall receive training on data security, privacy protection, and incident response.

12.1 Staffing Requirements

• HL Hunt shall maintain an adequate number of trained employees to handle the volume of disputes received without compromising timeliness or quality.
• Staffing levels shall be based on historical dispute volumes, projected trends, seasonal variations, and FCRA deadline requirements.
• Contingency staffing plans shall be maintained to address unexpected volume increases or staff absences.
• No dispute shall miss an FCRA deadline due to staffing constraints; additional resources shall be allocated as needed.

12.2 Capacity Review

• HL Hunt shall review, at regular intervals not less than monthly, whether staffing levels align with dispute volume.
• Key metrics monitored shall include: disputes received vs. processed, average processing time, backlog levels, deadline compliance rate, and quality scores.
• Staffing adjustments shall be made when metrics indicate capacity constraints.
• Capacity reviews shall be documented and reported to senior management.

12.3 Supervisory Oversight

• Supervisory personnel shall oversee dispute operations to ensure compliance, quality, and timeliness.
• Supervisors shall review pending dispute reports daily to identify approaching deadlines or processing issues.
• Escalation procedures shall be in place for disputes requiring management attention.
• Supervisory oversight activities shall be documented.

13.1 Quality Review Procedures

• A random sample of completed disputes shall be reviewed by quality assurance personnel on an ongoing basis.
• Quality reviews shall assess: thoroughness of investigation, accuracy of determination, appropriateness of response code, adequacy of documentation, timeliness of processing, and compliance with procedures.
• Minimum sample size shall be ten percent (10%) of disputes processed or fifty (50) disputes per month, whichever is greater.
• Quality scores shall be tracked by individual, team, and overall program.

13.2 Error Identification and Correction

• Errors identified through quality review shall be documented, categorized, and addressed through appropriate corrective measures.
• Significant errors affecting consumers shall be corrected immediately with updated information sent to CRAs.
• Root cause analysis shall be performed for recurring errors to identify systemic issues.
• Error trends shall be analyzed monthly to identify training needs or process improvements.

13.3 Performance Standards

• Target quality score: 95% or higher accuracy on quality reviews.
• Target timeliness: 100% of disputes responded to within FCRA deadlines.
• Target processing time: Average of 20 business days or less from receipt to response.
• Performance against standards shall be reported monthly to management.

14.1 Annual Policy Review

• This policy shall be reviewed at least annually by the Compliance Department in coordination with the Dispute Resolution Team.
• Reviews shall assess alignment with current FCRA requirements, CFPB guidance, and industry best practices.
• Findings and recommendations shall be documented and presented to the Policy Governance Committee.
• Policy updates shall be implemented within sixty (60) days of approval.

14.2 Policy Change Documentation

• All changes to this policy shall be documented with effective dates, rationale, and approval signatures.
• Employees shall receive training on material policy changes.
• Version history shall be maintained for audit purposes.

14.3 Compliance Audits

• Internal audits of dispute handling operations shall be conducted at least annually.
• Audits shall evaluate: FCRA compliance, investigation quality, documentation adequacy, timeliness, training compliance, and record retention.
• Audit findings shall be documented with corrective action plans for identified deficiencies.
• Audit reports shall be provided to senior management and the Compliance Committee.

14.4 Regulatory Examination Preparedness

• HL Hunt shall maintain documentation and records in a manner designed to facilitate regulatory examination by the CFPB, FTC, or state regulators.
• Policies, procedures, training records, dispute files, and audit reports shall be organized and accessible.
• Designated personnel shall be responsible for coordinating responses to regulatory inquiries.

15.1 Identity Theft Dispute Handling

• Disputes indicating that the account resulted from identity theft shall be routed to specialized fraud investigators.
• Identity theft disputes shall receive priority handling with a target resolution of ten (10) business days.
• Investigators shall review all available documentation to determine whether the account was opened fraudulently.
• If identity theft is confirmed, the account shall be deleted from the consumer's credit file and blocked from re-reporting.

15.2 Identity Theft Report Requirements

• Upon receipt of an identity theft report (police report or FTC Identity Theft Report) and proof of identity, HL Hunt shall block the disputed information within four (4) business days as required by FCRA § 1681c-2.
• Blocked information shall not be furnished to CRAs unless HL Hunt determines the block was based on material misrepresentation or the consumer obtained goods/services as a result of the blocked transaction.
• If HL Hunt declines to block or rescinds a block, written notification shall be provided to the consumer within five (5) business days.

15.3 Fraud Investigation

• Fraud investigations shall include review of: original account application, identity verification performed at account opening, signatures on file, address and contact information patterns, and account activity patterns.
• If fraud is suspected but not confirmed, additional verification may be requested from the consumer.
• Confirmed fraud shall be reported to appropriate law enforcement if required or appropriate.

15.4 Preventing Future Fraud

• Accounts confirmed as fraudulent shall be flagged in HL Hunt's systems to prevent re-opening or re-reporting.
• Fraud patterns shall be analyzed to improve identity verification procedures and prevent future fraudulent accounts.
• Information about confirmed fraud may be shared with fraud prevention networks as permitted by law.

16.1 Consumer Rights

• Consumers have the right to dispute any information HL Hunt has furnished to CRAs that they believe to be inaccurate.
• Consumers have the right to have disputes investigated thoroughly and within FCRA timeframes.
• Consumers have the right to receive notification of investigation results for direct disputes.
• Consumers have the right to request that corrections be reported to all CRAs.
• Consumers have the right to add a statement to their credit file if they disagree with investigation results.

16.2 Consumer Communications

• All communications with consumers regarding disputes shall be professional, clear, and respectful.
• Communications shall accurately describe consumer rights and the dispute process.
• Response letters shall clearly explain investigation findings and any actions taken.
• Contact information shall be provided for consumers with questions or concerns.

16.3 Status Inquiries

• Consumers may request status updates on pending disputes by contacting HL Hunt via the channels listed in Section 18.
• Status inquiries shall be responded to within two (2) business days.
• Status updates shall indicate: current stage of investigation, expected completion timeframe, and any additional information needed.

17.1 Employee Accountability

• All employees involved in dispute handling are expected to comply fully with these policies and procedures.
• Non-compliance may result in disciplinary action, including verbal warning, written warning, suspension, or termination.
• Intentional violations, falsification of records, or conduct causing consumer harm shall be treated as serious misconduct.
• Disciplinary actions shall be documented and reported to Human Resources.

17.2 Compliance Monitoring

• The Compliance Department shall monitor dispute handling operations for adherence to policies and regulatory requirements.
• Monitoring activities shall include: review of quality assurance results, timeliness metrics, audit findings, and consumer complaints.
• Compliance issues shall be escalated to senior management and addressed through corrective action.

17.3 Regulatory Reporting

• Compliance matters requiring regulatory notification shall be reported to appropriate authorities within mandated timeframes.
• Coordination with Legal Department shall be maintained for regulatory communications.
• Regulatory examination findings shall be addressed through formal corrective action plans.

18.1 Internal Contacts

• Dispute Resolution Manager: Responsible for day-to-day dispute operations and escalations.
• Compliance Department: Responsible for policy interpretation, regulatory matters, and audit coordination.
• Legal Department: Responsible for litigation matters and regulatory communications.
• Ethics Hotline: Available for reporting compliance concerns or policy violations.