1.1 Policy Purpose

• To establish standardized procedures for receiving, processing, investigating, and responding to disputes from business entities regarding credit information furnished by HL Hunt to business credit reporting agencies.
• To ensure compliance with industry standards, contractual obligations with credit bureaus, and applicable regulations governing business credit reporting.
• To define roles, responsibilities, and accountability structures for all personnel involved in business dispute handling operations.
• To protect the rights of business owners and guarantors 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 business credit information furnished by HL Hunt.

1.2 Scope of Application

• This policy applies to all disputes regarding business credit accounts and tradelines furnished by HL Hunt to Dun & Bradstreet, Experian Business, Equifax Business, and any other commercial credit reporting agencies.
• Covered disputes include challenges to: account ownership, account status, payment history, balance information, credit limits, high credit amounts, dates of activity, business identification information, and guarantor information.
• This policy governs disputes received through business credit bureau channels as well as direct disputes received from business owners, officers, guarantors, and authorized representatives.
• All business units, departments, and affiliated entities that furnish business credit data or participate in dispute handling are subject to these requirements.

1.3 Policy Objectives

• Process all business credit disputes within thirty (30) days of receipt, or sooner as required by bureau agreements.
• Conduct thorough and reasonable investigations of all disputed information using all relevant records and documentation.
• Report accurate investigation results to business credit bureaus 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 business disputants regarding their rights and resolution outcomes.

2.1 Business Credit Definitions

• "Business Credit Bureau" refers to commercial credit reporting agencies including Dun & Bradstreet (D&B), Experian Business, Equifax Business, and other agencies that compile and report business credit information.
• "Business Credit Report" refers to any report containing information about a business entity's credit history, payment behavior, financial obligations, and related commercial information.
• "Business Tradeline" refers to the commercial credit account record that HL Hunt furnishes to business credit bureaus, including all associated data elements.
• "PAYDEX Score" refers to Dun & Bradstreet's proprietary business credit score ranging from 1-100 based on payment history.
• "Intelliscore" refers to Experian's business credit score predicting likelihood of serious delinquency.
• "Business Credit Risk Score" refers to Equifax's commercial credit scoring model.

2.2 Entity and Party Definitions

• "Business Entity" refers to any corporation, limited liability company, partnership, sole proprietorship, or other legal entity about which HL Hunt furnishes credit information.
• "Business Owner" refers to any individual with an ownership interest in the business entity, including shareholders, members, partners, and sole proprietors.
• "Authorized Officer" refers to corporate officers, directors, or executives with legal authority to act on behalf of the business entity (CEO, CFO, President, etc.).
• "Personal Guarantor" refers to any individual who has personally guaranteed the obligations of the business entity and whose information may appear in connection with the business credit file.
• "Authorized Representative" refers to any third party with written authorization to submit disputes on behalf of the business entity or guarantor.
• "D-U-N-S Number" refers to the unique nine-digit identifier assigned by Dun & Bradstreet to business entities.
• "EIN" refers to the Employer Identification Number assigned by the IRS to business entities.

2.3 Dispute-Related Definitions

• "Dispute" refers to a business entity's or guarantor's challenge to the accuracy, completeness, or verifiability of information HL Hunt has furnished to a business credit bureau.
• "Bureau-Forwarded Dispute" refers to a dispute submitted by a business to a credit bureau, which is then forwarded to HL Hunt for investigation and response.
• "Direct Dispute" refers to a dispute submitted directly to HL Hunt by the business entity, guarantor, or authorized representative.
• "Reinvestigation" refers to the investigation conducted by HL Hunt upon receipt of a dispute to verify or correct reported information.
• "System of Record" refers to HL Hunt's authoritative database(s) containing original account information used to verify disputed data.

3.1 Applicable Regulations

• Fair Credit Reporting Act (FCRA): While primarily focused on consumer credit, certain FCRA provisions may apply to business credit reports that contain personal guarantor information or are used for consumer purposes.
• State Commercial Credit Laws: Various states have enacted laws governing business credit reporting and dispute resolution, which HL Hunt monitors and complies with as applicable.
• FTC Act § 5: Prohibits unfair or deceptive acts or practices, which applies to business credit reporting activities.
• Contractual Obligations: HL Hunt's agreements with business credit bureaus establish specific requirements for data accuracy, dispute handling, and response timeframes.

3.2 Bureau-Specific Requirements

Each business credit bureau has specific requirements for dispute handling:

• Dun & Bradstreet: Disputes received through D&B's iUpdate system or direct channels must be investigated and responded to within thirty (30) days. Updates are submitted through D&B's data submission processes.
• Experian Business: Disputes are processed through Experian's business dispute resolution system with response required within thirty (30) days. Updates submitted via Experian's commercial data furnishing platform.
• Equifax Business: Disputes processed through Equifax's commercial dispute system with investigation and response within thirty (30) days. Updates submitted through designated data transmission channels.

3.3 Investigation Timeframes

• HL Hunt shall complete investigations of bureau-forwarded disputes and report results within thirty (30) days of receiving the dispute notification.
• 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 (20) business days to allow adequate time for bureau transmission and processing.
• Expedited handling (fifteen business days) is available for disputes involving documented fraud or imminent business harm.

3.4 Industry Best Practices

• HL Hunt follows industry best practices established by the Consumer Data Industry Association (CDIA) for commercial data furnishing.
• Dispute handling procedures align with guidance from business credit bureau industry groups and trade associations.
• HL Hunt participates in industry forums and monitors emerging standards for business credit reporting.

4.1 Bureau-Forwarded Dispute Intake

• Disputes forwarded from business credit bureaus are received through designated electronic systems or secure communication channels established with each bureau.
• All incoming bureau disputes shall be logged in the Business Dispute Management System within one (1) business day of receipt with assignment of unique tracking identifiers.
• Disputes shall be routed to the Business Dispute Resolution Team for investigation based on dispute type, complexity, and bureau source.
• System alerts shall notify supervisory personnel of approaching 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: Business claims they do not have an account with HL Hunt or did not authorize the account.
• Account Status Disputes: Business disputes the reported status (open, closed, charged-off, in collection, etc.).
• Balance/Credit Limit Disputes: Business disputes the reported balance, credit limit, high credit, or credit utilization.
• Payment History Disputes: Business disputes reported late payments, Days Beyond Terms (DBT), or payment patterns.
• Business Information Disputes: Business disputes reported legal name, EIN, D-U-N-S Number, address, SIC/NAICS code, or other identifying information.
• Guarantor Disputes: Personal guarantor disputes information reported about their guarantee or personal information.
• Fraud/Identity Theft Disputes: Business claims account resulted from business identity theft or fraud.
• Date-Related Disputes: Business disputes account open date, close date, or date of first delinquency.
• Duplicate Account Disputes: Business claims account is reported multiple times or is a duplicate of another tradeline.

4.3 Priority Handling

• Fraud and business identity theft disputes shall receive priority handling and be assigned to senior investigators.
• Disputes approaching deadline (within 5 business days) shall be escalated for expedited processing.
• Disputes involving regulatory complaints, legal matters, or executive escalations shall receive priority handling.
• Disputes from businesses with documented imminent credit decisions (pending loans, contracts) may receive expedited handling upon request.
• Standard disputes shall be processed in the order received, subject to priority classifications.

5.1 Response Requirements

• HL Hunt shall respond to all bureau-forwarded disputes within the timeframe specified by each bureau's furnisher agreement (generally 30 days), targeting response submission at least five (5) business days before the deadline.
• Responses shall accurately reflect the results of HL Hunt's investigation using appropriate response codes as specified by each bureau.
• 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 bureau responses shall be reviewed by a supervisor or quality assurance personnel before submission for disputes involving account deletion or significant modifications.

5.2 Dun & Bradstreet Response Procedures

• D&B disputes received through iUpdate or direct communication shall be responded to within thirty (30) days.
• Responses shall utilize D&B's designated response codes and formats.
• Account updates shall be submitted through D&B's approved data transmission methods.
• Confirmation of response submission shall be retained for compliance records.
• If investigation reveals inaccurate information, updates shall be submitted to D&B promptly.

5.3 Experian Business Response Procedures

• Experian Business disputes shall be responded to within thirty (30) days through Experian's commercial dispute system.
• Responses shall utilize Experian's designated response codes and formats.
• Account corrections shall be submitted through Experian's commercial data furnishing platform.
• Response confirmations shall be documented and retained.

5.4 Equifax Business Response Procedures

• Equifax Business disputes shall be responded to within thirty (30) days through Equifax's designated channels.
• Responses shall follow Equifax's specified format and code requirements.
• Account updates shall be transmitted through established data submission processes.
• Response documentation shall be maintained for compliance purposes.

5.5 Multi-Bureau Updates

• If investigation reveals that disputed information is inaccurate or incomplete, HL Hunt shall report corrections to ALL business credit bureaus to which the information was previously furnished.
• Multi-bureau updates shall be submitted within five (5) business days of investigation completion.
• Documentation shall confirm that all applicable bureaus received corrected information.
• Regular reporting cycles shall be updated to reflect any corrections.

6.1 Eligible Disputants

• Business Owners: Any individual who is a legal owner, partner, member, or shareholder of the business entity.
• Authorized Officers: Corporate officers, directors, or executives with legal authority to act on behalf of the business (CEO, CFO, President, etc.).
• Personal Guarantors: Any individual who has personally guaranteed obligations of the business and whose information appears in connection with the business credit file.
• Authorized Representatives: Third parties with written authorization signed by an eligible disputant, including attorneys and designated agents.

6.2 Direct Dispute Intake Channels

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

6.3 Required Dispute Information

Direct disputes must include sufficient information to investigate:

• Business legal name, EIN, D-U-N-S Number (if known), and address.
• Name, title, and contact information of the person submitting the dispute.
• Documentation establishing authority to dispute on behalf of the business (if applicable).
• Specific identification of the information being disputed.
• Explanation of why the information is believed to be inaccurate.
• Supporting documentation (if available).

6.4 Direct Dispute Processing

• Direct disputes meeting investigation requirements shall be logged in the Business Dispute Management System within two (2) business days of receipt.
• Acknowledgment of receipt shall be sent to the disputant 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 disputant of additional information needed within five (5) business days.
• Written notification of investigation results shall be sent to the disputant within five (5) business days of completing the investigation.

6.5 Verification of Disputant Authority

• For disputes submitted by business owners or officers, HL Hunt may verify authority through Secretary of State records, corporate documents, or direct business contact.
• For disputes submitted by authorized representatives, written authorization must be on file before investigation proceeds.
• Disputes from individuals who cannot establish authority may be declined pending verification.

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 bureau or disputant, including business 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, credit agreements, personal guarantees, and enrollment forms.
• Payment Records: Payment history, transaction logs, remittance records, and bank deposit records.
• Correspondence Files: Letters, emails, and other communications with the business.
• Business Verification Records: Documentation used to verify business identity at account opening (EIN verification, Secretary of State filings, etc.).
• Guarantor Documentation: Personal guarantee agreements, guarantor identification, and related records.
• Third-Party Records: Information from collection agencies, credit bureaus, public records, or other sources as applicable.
• Secretary of State Records: Business registration, officer information, and corporate status.

7.3 Account Ownership Verification

• For disputes challenging account ownership, investigators shall verify the business entity's identity against original account documentation.
• Verification shall include comparison of: business legal name, EIN, D-U-N-S Number, address, and authorized signers.
• If account documentation contains signatures, they may be compared against known signatures of authorized officers.
• Secretary of State records may be consulted to verify business existence and officer authority.
• If ownership cannot be verified through available documentation, the account shall be deleted from the business'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, invoice references, and application shall be verified against system records.
• Days Beyond Terms (DBT) calculations shall be verified against payment due dates and actual receipt dates.
• 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 business'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.
• Evidence reviewed shall be retained or referenced in the dispute file.

8.1 Business Validation Procedures

• Upon receipt of any dispute, HL Hunt shall validate the business entity's identifying information against account records to confirm the dispute pertains to the correct account.
• Validation shall include comparison of: business legal name (including DBA names), EIN, D-U-N-S Number (if available), business address, and registered agent information.
• If identifying information on the dispute does not match account records, additional verification steps shall be taken before proceeding with investigation.
• Discrepancies in business identification shall be documented and may indicate potential mixed file or fraud issues requiring special handling.

8.2 Entity Verification Sources

• IRS EIN Verification: Confirmation of EIN assignment to the business entity.
• Secretary of State Records: Business registration, formation documents, officer listings, and current status.
• D-U-N-S Number Verification: Confirmation of D&B identifier assignment.
• Business Licenses: State and local business license records.
• Physical Address Verification: Confirmation of business location through various databases.

8.3 Mixed File Identification

• If validation suggests the disputed account may belong to a different business entity (mixed file), investigators shall conduct enhanced review to determine correct ownership.
• Mixed file situations may occur due to: similar business names, shared addresses, common principals, or data entry errors.
• Mixed file situations shall be escalated to senior investigators for determination.
• If HL Hunt determines that account information was reported to the wrong business's credit file, immediate correction shall be submitted to all bureaus.

8.4 Business Identity Theft Indicators

• Validation shall include review for business identity theft indicators, including: recently changed registered agent, address changes to unfamiliar locations, unauthorized officer changes, and multiple disputes from the same EIN with different contact information.
• If business identity theft is suspected, the dispute shall be routed to the Fraud team for specialized handling under Section 16.

9.1 Guarantor Dispute Rights

• Personal guarantors have the right to dispute information reported about their guarantee or personal information appearing in connection with a business tradeline.
• Guarantor disputes may challenge: the existence of a guarantee, the terms of a guarantee, personal identification information, or the accuracy of guarantee-related reporting.
• Guarantor disputes shall be handled with the same diligence and timeframes as business entity disputes.

9.2 Guarantor Verification

• For disputes challenging the existence of a guarantee, investigators shall locate and review the original personal guarantee agreement.
• Guarantee verification shall include: confirmation of guarantor signature, verification of guarantor identity information, and review of guarantee terms.
• If no signed guarantee can be located, guarantee information shall be removed from reporting.
• If the guarantee signature appears inconsistent with known signatures, additional verification may be required.

9.3 Guarantor Information Disputes

• For disputes regarding guarantor personal information (name, SSN, address), investigators shall verify reported information against guarantee documentation and supporting records.
• Inaccurate guarantor information shall be corrected with all bureaus.
• If guarantor information cannot be verified, it shall be removed or updated to reflect only verifiable data.

9.4 Consumer Credit Implications

• If guarantor disputes relate to information that may also appear on consumer credit reports, the dispute shall be coordinated with personal credit dispute handling procedures.
• FCRA requirements shall apply to any consumer credit reporting aspects of guarantor information.
• Corrections to guarantor information shall be applied consistently across business and consumer reporting as applicable.

10.1 Required Documentation

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

10.2 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.
• Bureau agreements specifying longer retention periods shall be followed.
• Electronic records shall be maintained in a format that preserves integrity and permits accurate reproduction.

10.3 Record Security

• Dispute records containing business or guarantor information 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.

11.1 Correction Procedures

• When investigation determines that disputed information is inaccurate or incomplete, HL Hunt shall promptly update the information with all business credit bureaus to which it was previously furnished.
• Corrections shall be submitted via bureau-specific response systems and regular reporting updates.
• All corrections shall be processed within five (5) business days of investigation completion.
• Confirmation of correction submission shall be documented in the dispute file.

11.2 Deletion Procedures

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

11.3 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.

11.4 Disputant Notification

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

12.1 Initial Training Requirements

• All employees assigned to business dispute handling roles shall complete comprehensive initial training before processing disputes independently.
• Initial training curriculum shall include: business credit bureau relationships and requirements, D&B/Experian Business/Equifax Business systems and processes, investigation procedures and documentation standards, business entity verification methods, guarantor dispute handling, and data security requirements.
• 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.

12.2 Annual Recertification

• All business dispute handling personnel shall complete annual recertification training to maintain current knowledge.
• Recertification shall address: bureau requirement 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.

12.3 Specialized Training

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

13.1 Staffing Requirements

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

13.2 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.

13.3 Supervisory Oversight

• Supervisory personnel shall oversee business 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.

14.1 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, 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.

14.2 Error Identification and Correction

• Errors identified through quality review shall be documented, categorized, and addressed through appropriate corrective measures.
• Significant errors affecting businesses shall be corrected immediately with updated information sent to bureaus.
• 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.

14.3 Performance Standards

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

15.1 Annual Policy Review

• This policy shall be reviewed at least annually by the Compliance Department in coordination with the Business Dispute Resolution Team.
• Reviews shall assess alignment with current bureau requirements, industry standards, and 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.

15.2 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.

15.3 Compliance Audits

• Internal audits of business dispute handling operations shall be conducted at least annually.
• Audits shall evaluate: bureau 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.

15.4 Bureau Relationship Management

• HL Hunt shall maintain positive relationships with business credit bureaus through compliance with furnisher agreements and timely dispute resolution.
• Bureau communications regarding dispute handling performance shall be reviewed and addressed promptly.
• Any bureau concerns or deficiencies shall be escalated and resolved through corrective action.

16.1 Business Identity Theft Handling

• Disputes indicating that the account resulted from business identity theft shall be routed to specialized fraud investigators.
• Business 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 business identity theft is confirmed, the account shall be deleted from the business's credit file and blocked from re-reporting.

16.2 Fraud Investigation Procedures

• Fraud investigations shall include review of: original account application, business verification performed at account opening, signatures on file, address and contact information patterns, and account activity patterns.
• Secretary of State records shall be consulted to verify business legitimacy and authorized signers.
• If fraud is suspected but not confirmed, additional verification may be requested from the disputant.
• Confirmed fraud shall be documented and may be reported to appropriate authorities.

16.3 Indicators of Fraudulent Disputes

• HL Hunt monitors for indicators of fraudulent or bad-faith disputes, including: disputes filed by unauthorized parties, disputes contradicted by clear documentation, patterns of frivolous disputes, and disputes designed to remove accurate negative information.
• Suspected fraudulent disputes shall be flagged and reviewed by senior investigators.
• HL Hunt reserves the right to verify accurate information despite dispute challenges where documentation clearly supports the reported information.

16.4 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 business verification procedures and prevent future fraudulent accounts.
• Information about confirmed fraud may be shared with fraud prevention networks and bureaus as appropriate.

17.1 Business Rights

• Businesses have the right to dispute any information HL Hunt has furnished to business credit bureaus that they believe to be inaccurate.
• Businesses have the right to have disputes investigated thoroughly and within established timeframes.
• Businesses have the right to receive notification of investigation results for direct disputes.
• Businesses have the right to request that corrections be reported to all business credit bureaus.
• Businesses have the right to add a statement to their credit file if they disagree with investigation results (where supported by the bureau).
• Businesses have the right to escalate disputes if not satisfied with initial resolution.

17.2 Business Communications

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

17.3 Status Inquiries

• Businesses may request status updates on pending disputes by contacting HL Hunt via the channels listed in Section 19.
• 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.

17.4 Escalation Process

• Businesses dissatisfied with dispute outcomes may request escalation to the Business Dispute Resolution Manager.
• Escalation requests shall be reviewed within five (5) business days.
• Escalated disputes shall be re-reviewed by senior personnel not involved in the original investigation.
• Final determinations shall be communicated in writing with explanation of findings.

18.1 Employee Accountability

• All employees involved in business 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 harm to businesses shall be treated as serious misconduct.
• Disciplinary actions shall be documented and reported to Human Resources.

18.2 Compliance Monitoring

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

18.3 Bureau Reporting

• Performance metrics and compliance status shall be reported to business credit bureaus as required by furnisher agreements.
• Any significant compliance issues shall be disclosed to bureaus as appropriate.
• HL Hunt shall respond promptly to bureau inquiries regarding dispute handling practices.

19.1 Internal Contacts

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