HL Hunt | FCRA Compliance and Consumer Rights Disclosure

Federal Consumer Protection Disclosure

HL Hunt

FCRA Compliance and Consumer Rights Disclosure

HL Hunt Credit Builder Program — Personal and Business

Furnisher HL Hunt Inc. / HL Hunt Lending LLC

Address 3499 Blazer Parkway, Lexington, KY 40509

Effective Date July 23, 2025

Compliance Contact compliance@hlhunt.org

HL Hunt Inc. and HL Hunt Lending LLC (collectively, "HL Hunt," "we," "us," or "our") are committed to full compliance with the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq., and all applicable state and federal consumer protection laws. This disclosure outlines your rights, our obligations as a data furnisher, and your options as a participant in the HL Hunt Credit Builder Program, which includes credit reporting to one or more consumer or commercial credit bureaus. Please read this disclosure carefully and retain it for your records.

1. Purpose of Credit Reporting

As a participant in the HL Hunt Credit Builder Program, your account activity may be reported to consumer and/or commercial credit reporting agencies. The purpose of this reporting is to establish, build, or enhance your credit history by creating a verifiable tradeline that reflects your payment behavior with HL Hunt.

1.1 Consumer Credit Reporting Agencies

For personal/individual accounts, HL Hunt may report to the following Consumer Reporting Agencies (CRAs):

Equifax — www.equifax.com — 1-800-685-1111
Experian — www.experian.com — 1-888-397-3742
TransUnion — www.transunion.com — 1-800-916-8800

1.2 Business Credit Reporting Agencies

For business entity accounts, HL Hunt may report to the following commercial credit bureaus:

Dun & Bradstreet — www.dnb.com
Experian Business — www.experian.com/business
Equifax Business — www.equifax.com/business

Important Notice

HL Hunt does not guarantee that your account will be reported to any specific credit bureau, that any credit bureau will accept or display reported information, or that any credit score improvement will result from participation. Credit bureaus are independent third parties with their own policies and procedures over which HL Hunt has no control. See Section 10 for complete disclaimers.

2. Information We Report

HL Hunt may report the following information about your Credit Builder account to applicable credit reporting agencies:

Data Element	Description
Account Opening Date	Date your HL Hunt Credit Line was activated
Account Closing Date	Date your account was closed (if applicable)
Credit Limit / High Credit	Your approved credit limit amount
Current Balance	Outstanding Credit Line Balance at time of reporting
Credit Utilization	Percentage of credit limit currently in use
Payment History	Record of on-time, late, or missed payments (based on Monthly Maintenance Fee)
Account Status	Current, delinquent, charged-off, closed, or other status codes
Date of Last Payment	Most recent payment received
Date of First Delinquency	If applicable, the date account first became delinquent
Account Type	Revolving credit account

Payment History Reporting

Your payment history is based on your timely payment of the Monthly Maintenance Fee. On-time payment of the Monthly Maintenance Fee may be reported as positive payment activity. Late or missed Monthly Maintenance Fee payments may be reported as delinquent activity. Balance Payments (voluntary payments to reduce your Credit Line Balance) affect your reported balance and utilization but are not separately reported as payment activity.

3. Permissible Purpose for Accessing Your Credit

By applying for and using HL Hunt services, you authorize HL Hunt to obtain your credit report for the following permissible purposes under FCRA § 604 (15 U.S.C. § 1681b):

Credit Transaction: To evaluate your eligibility for HL Hunt membership and a Credit Line in connection with a credit transaction initiated by you.
Identity Verification: To verify your identity and prevent fraud in connection with your application.
Account Review: To review and monitor your account on an ongoing basis in connection with the existing credit relationship.
Credit Limit Decisions: To determine eligibility for credit limit increases, account renewals, or membership tier changes.
Collection Activities: To collect on amounts owed in connection with a delinquent or defaulted account.
Legal Compliance: To comply with legal, regulatory, or court-ordered obligations.

We will only access your credit file in accordance with the permissible purposes outlined above and as authorized under the FCRA. We do not access your credit file for marketing purposes without your express consent.

4. Your Right to Accuracy and Correction

Under the Fair Credit Reporting Act (FCRA), you have important rights regarding the accuracy of information in your credit file:

Your FCRA Rights Include:

Right to Be Informed: You have the right to be informed if information in your credit file has been used against you in connection with a credit, employment, insurance, or other decision.
Right to Access Your Credit Report: You have the right to obtain a free copy of your credit report from each of the three major consumer reporting agencies (Equifax, Experian, TransUnion) once every twelve (12) months at www.annualcreditreport.com.
Right to Dispute: You have the right to dispute inaccurate, incomplete, or unverifiable information in your credit report directly with the credit reporting agency or with the furnisher (HL Hunt).
Right to Timely Investigation: Upon receiving your dispute, the credit reporting agency must conduct a reasonable investigation, typically within thirty (30) days, and provide you with the results.
Right to Correction: If the investigation reveals that the disputed information is inaccurate, incomplete, or unverifiable, the credit reporting agency must correct or delete the information.
Right to Add a Statement: If your dispute is not resolved to your satisfaction, you have the right to add a brief consumer statement to your credit file explaining any disputed item.
Right to Notification: You have the right to request that the credit reporting agency notify anyone who received your credit report within the past two years (for employment purposes) or six months (for other purposes) of any corrections.

5. Dispute Resolution Procedures

If you believe that any information HL Hunt has reported about your account is inaccurate, incomplete, or unverifiable, you have the right to dispute that information. You may file a dispute in the following ways:

5.1 Dispute Directly with HL Hunt (Direct Dispute)

You may submit a dispute directly to HL Hunt in writing. Your dispute should include:

Your full name and current address
Your HL Hunt account number (if known)
Identification of the specific information you are disputing
An explanation of why you believe the information is inaccurate
Any supporting documentation

HL Hunt Dispute Resolution

Email: compliance@hlhunt.org

Mail: HL Hunt Compliance Department, 3499 Blazer Parkway, Lexington, KY 40509

Subject Line: "FCRA Dispute — [Your Name]"

Upon receipt of a complete dispute, HL Hunt will conduct a reasonable investigation within thirty (30) days and notify you of the results. If we determine that the disputed information is inaccurate or unverifiable, we will correct or delete the information and notify all credit reporting agencies to which we furnished the information.

5.2 Dispute with Credit Reporting Agencies (Indirect Dispute)

You may also dispute information by contacting the credit reporting agency directly. When a credit bureau notifies HL Hunt of your dispute, we will:

Conduct a reasonable investigation of the disputed information
Review all relevant information provided by the credit bureau
Report the results of the investigation to the credit bureau
Correct, modify, or delete inaccurate or unverifiable information
Notify all credit bureaus to which we report if corrections are made

5.3 Investigation Timeline

Stage	Timeframe	Action
Dispute Receipt	Within 5 business days	Acknowledgment sent to consumer
Investigation	Within 30 days (or 45 days if additional info provided)	Review of records and documentation
Resolution	Within 5 business days of determination	Consumer notified of results; corrections reported to bureaus

6. Adverse Action Notices

If HL Hunt takes adverse action against you based in whole or in part on information contained in a consumer credit report, we will provide you with an Adverse Action Notice in accordance with FCRA § 615(a) (15 U.S.C. § 1681m). Adverse actions may include:

Denial of your application for membership or a Credit Line
Denial of a request for a credit limit increase
Reduction of your existing credit limit
Suspension or termination of your account
Offering less favorable terms than those requested

6.1 Contents of Adverse Action Notice

The Adverse Action Notice will include:

The name, address, and telephone number of the consumer reporting agency that supplied the report used in the decision
A statement that the consumer reporting agency did not make the adverse decision and cannot explain why the decision was made
Notice of your right to obtain a free copy of your credit report from the reporting agency within sixty (60) days
Notice of your right to dispute the accuracy or completeness of any information in the report
If applicable, your credit score and information about how the score was used in the decision

7. Summary of Your FCRA Rights

The Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq., promotes the accuracy, fairness, and privacy of information in the files of consumer reporting agencies. Below is a summary of your major rights under the FCRA:

Summary of Consumer Rights Under the FCRA

You must be told if information in your file has been used against you. Anyone who uses a credit report or another type of consumer report to deny your application for credit, insurance, or employment — or to take another adverse action against you — must tell you and give you the name, address, and phone number of the agency that provided the information.
You have the right to know what is in your file. You may request and obtain all the information about you in the files of a consumer reporting agency. You will be required to provide proper identification.
You have the right to ask for a credit score. Credit scores are numerical summaries of your creditworthiness based on information from credit bureaus.
You have the right to dispute incomplete or inaccurate information. If you identify information in your file that is incomplete or inaccurate and report it to the consumer reporting agency, the agency must investigate unless your dispute is frivolous.
Consumer reporting agencies must correct or delete inaccurate, incomplete, or unverifiable information. Inaccurate, incomplete, or unverifiable information must be removed or corrected, usually within 30 days.
Consumer reporting agencies may not report outdated negative information. In most cases, a consumer reporting agency may not report negative information that is more than seven years old, or bankruptcies that are more than 10 years old.
Access to your file is limited. A consumer reporting agency may provide information about you only to people with a valid need — usually to consider an application with a creditor, insurer, employer, landlord, or other business.
You must give your consent for reports to be provided to employers. A consumer reporting agency may not give out information about you to your employer, or a potential employer, without your written consent.
You may limit "prescreened" offers of credit and insurance you get based on information in your credit report. Unsolicited "prescreened" offers for credit and insurance must include a toll-free phone number you can call to remove your name from lists used to make such offers.
You may seek damages from violators. If a consumer reporting agency, or in some cases a user of consumer reports or a furnisher of information to a consumer reporting agency, violates the FCRA, you may be able to sue in state or federal court.
Identity theft victims and active duty military personnel have additional rights. For more information, visit www.consumerfinance.gov/learnmore.

For more information about your rights under the FCRA, visit the Consumer Financial Protection Bureau at:

www.consumerfinance.gov/learnmore

or write to: Consumer Financial Protection Bureau, 1700 G Street N.W., Washington, DC 20552.

8. Identity Theft Protections

The FCRA provides special protections for victims of identity theft:

8.1 Your Rights as an Identity Theft Victim

Fraud Alerts: You may place an initial fraud alert on your credit file by contacting any one of the three major credit bureaus. That bureau must notify the other two bureaus. An initial fraud alert lasts one year and can be renewed.
Extended Fraud Alert: Identity theft victims with a police report or identity theft report may place an extended fraud alert lasting seven years.
Credit Freeze: You may place a security freeze on your credit file, which prohibits consumer reporting agencies from releasing your credit report without your authorization. Freezes are free.
Free Credit Reports: Identity theft victims are entitled to additional free credit reports beyond the annual free report.
Blocking of Fraudulent Information: You may request that consumer reporting agencies block the reporting of information that resulted from identity theft.

8.2 If You Suspect Identity Theft Involving HL Hunt

If you believe that an account was opened with HL Hunt fraudulently using your identity, or that your HL Hunt account has been compromised, please contact us immediately:

Email: compliance@hlhunt.org with subject line "Identity Theft Report"
Include a copy of your FTC Identity Theft Report or police report
Provide proof of your identity

HL Hunt will investigate identity theft claims promptly and, if fraud is confirmed, will delete the fraudulent account and notify all credit bureaus to which the account was reported.

8.3 Identity Theft Resources

FTC Identity Theft Website: www.identitytheft.gov
FTC Identity Theft Hotline: 1-877-438-4338
Annual Credit Report: www.annualcreditreport.com

9. Data Security and Retention

HL Hunt maintains strict information security protocols to safeguard your personal and credit information, consistent with FCRA § 628 (15 U.S.C. § 1681w) and the Gramm-Leach-Bliley Act (GLBA).

9.1 Security Measures

Encryption of data at rest and in transit using industry-standard protocols
Access controls limiting sensitive information to authorized personnel only
Multi-factor authentication for system access
Regular security assessments and vulnerability testing
Employee training on data security and privacy
Incident response procedures for potential data breaches

9.2 Data Sharing

We do not sell your personal or credit information to third parties for marketing purposes.
We share information with credit reporting agencies as described in this disclosure.
We may share information with service providers who assist us in operating our business, subject to confidentiality agreements.
We may disclose information when required by law, court order, or regulatory requirement.
We may share information in connection with a merger, acquisition, or sale of assets.

9.3 Data Retention

Account records are retained for a minimum of seven (7) years following account closure.
Dispute records are retained for a minimum of seven (7) years following resolution.
Records may be retained longer if required by law or for ongoing legal matters.
Upon expiration of retention periods, records are securely destroyed.

10. No Guarantee of Credit Outcomes

Important Disclaimers — No Guarantees

HL Hunt makes no guarantees, representations, or warranties regarding any credit-related outcomes as a result of your participation in the Credit Builder Program:

NO GUARANTEE that your account will be reported to any credit bureau
NO GUARANTEE that any credit bureau will accept, process, or display reported information
NO GUARANTEE of any credit score increase or improvement
NO GUARANTEE of any specific point increase (1, 10, 50, 100, or any amount)
NO GUARANTEE of approval for any loan, credit card, mortgage, auto loan, or other credit product
NO GUARANTEE of improved creditworthiness or lending terms
NO GUARANTEE that reported information will remain on your credit file for any period of time

Credit bureaus are independent third parties with their own policies, procedures, and algorithms over which HL Hunt has no control. Credit scores are determined by credit bureaus using proprietary models that HL Hunt does not influence. Individual results vary based on numerous factors including your complete credit history, other accounts, public records, and credit bureau policies.

11. Special Notice to Business Entities

Business Credit Reporting Notice

If you are a business entity using HL Hunt's Business Credit Builder Program, please be aware of the following:

Commercial Credit Reporting: HL Hunt may report your payment activity to commercial credit bureaus including Dun & Bradstreet, Experian Business, and Equifax Business.
FCRA Applicability: Commercial credit files are generally not governed by the Fair Credit Reporting Act (FCRA). The FCRA primarily applies to consumer credit reports used for personal, family, or household purposes.
Voluntary Standards: Although not required by law for commercial reporting, HL Hunt voluntarily applies many of the same accuracy, dispute resolution, and data security principles to business credit reporting as we do to consumer credit reporting.
Dispute Process: Business tradeline disputes should be submitted in writing to compliance@hlhunt.org with relevant documentation, including proof of authority to dispute on behalf of the business entity.
Guarantor Information: If you are a personal guarantor for a business account, information about your guarantee may be reported in connection with the business tradeline. Guarantor disputes are handled in accordance with applicable law.

For more information about business credit reporting practices, contact the commercial credit bureaus directly or visit their websites.

12. Regulatory Resources

The following resources provide additional information about your rights under the FCRA and other consumer protection laws:

Resource	Website	Phone
Consumer Financial Protection Bureau (CFPB)	www.consumerfinance.gov	1-855-411-2372
Federal Trade Commission (FTC)	www.ftc.gov	1-877-382-4357
Annual Credit Report	www.annualcreditreport.com	1-877-322-8228
Identity Theft Resource Center	www.idtheftcenter.org	1-888-400-5530
FTC Identity Theft	www.identitytheft.gov	1-877-438-4338

Full FCRA Regulations: A complete copy of the FCRA regulations is available at:

www.consumerfinance.gov/rules-policy/regulations/1022/

13. Consent and Acknowledgment

By Enrolling in the HL Hunt Credit Builder Program, You Certify That:

You understand that your account activity may be reported to one or more consumer or commercial credit reporting agencies.
You authorize HL Hunt to access and use your credit file for permissible purposes as described in Section 3 of this disclosure.
You have reviewed and understand your rights under the Fair Credit Reporting Act (FCRA) as summarized in this disclosure.
You understand the dispute resolution process and procedures for disputing inaccurate information.
You understand that HL Hunt does NOT guarantee any credit score increase, credit bureau posting, or credit approval from any lender.
You understand that the Monthly Maintenance Fee is a separate obligation that does NOT reduce your Credit Line Balance.
You understand that your Credit Line Balance must be paid separately through voluntary Balance Payments.
You acknowledge that you have received this FCRA Compliance and Consumer Rights Disclosure.
You voluntarily agree to participate in the Credit Builder Program under these terms.

14. Contact Information

HL Hunt Inc. / HL Hunt Lending LLC

Mailing Address: 3499 Blazer Parkway, Lexington, KY 40509

Website: www.hlhunt.org

General Support: support@hlhunt.org

Compliance Department: compliance@hlhunt.org

Dispute Resolution: compliance@hlhunt.org (Subject: "FCRA Dispute")

Identity Theft Reports: compliance@hlhunt.org (Subject: "Identity Theft Report")

All disputes, identity theft reports, and compliance inquiries should be submitted in writing to ensure proper documentation and timely response.

Document Information

Effective Date: July 23, 2025 | Version: 5.0.0 | Last Updated: July 23, 2025

This disclosure is provided in accordance with the Fair Credit Reporting Act (15 U.S.C. § 1681 et seq.) and Regulation V (12 CFR Part 1022). HL Hunt reserves the right to update this disclosure from time to time. Material changes will be communicated to participants.