HL Hunt Data Furnisher Policies and Procedures

HL Hunt | Data Furnisher Policies and Procedures

Preamble & Scope of Application

This policy establishes the comprehensive framework governing all data furnishing activities conducted by HL Hunt ("the Company," "we," "our," or "us") to consumer reporting agencies (CRAs). These policies and procedures ensure the accuracy, integrity, and regulatory compliance of all consumer information reported to credit bureaus including Equifax, Experian, TransUnion, and specialty consumer reporting agencies.

The provisions herein apply to all employees, contractors, subsidiaries, affiliates, and third-party service providers involved in the collection, processing, verification, and transmission of consumer data to CRAs. This policy is designed to ensure strict compliance with the Fair Credit Reporting Act (FCRA), as amended by the Fair and Accurate Credit Transactions Act (FACTA), the Consumer Financial Protection Bureau (CFPB) regulations, Metro 2 Format standards established by the Consumer Data Industry Association (CDIA), and all applicable state laws governing credit reporting.

Non-compliance with these policies may result in disciplinary action up to and including termination of employment or contract, and may expose the Company and/or individuals to regulatory enforcement actions, civil liability, and reputational harm.

1. Purpose and Scope

This policy establishes the authoritative framework for all data furnishing activities to ensure consistent, accurate, and compliant reporting of consumer information to credit reporting agencies.

1.1 Policy Objectives

Establish standardized procedures for the accurate and timely furnishing of consumer credit information to all designated consumer reporting agencies.
Ensure full compliance with the Fair Credit Reporting Act (FCRA), CFPB Regulation V, Metro 2 Format specifications, and all applicable federal and state regulations.
Define roles, responsibilities, and accountability structures for all personnel and third parties involved in data furnishing operations.
Protect consumer rights through accurate reporting and efficient dispute resolution processes.
Minimize regulatory, legal, and reputational risk through robust compliance controls and governance structures.

1.2 Scope of Application

This policy applies to all consumer credit information furnished to nationwide consumer reporting agencies (Equifax, Experian, TransUnion) and specialty CRAs.
Covered data includes, but is not limited to: account identification, payment history, credit limits, account balances, account status codes, and consumer demographic information.
All business units, departments, subsidiaries, and affiliated entities that furnish consumer data are subject to these requirements.
Third-party service providers, vendors, and contractors performing data furnishing functions on behalf of the Company must contractually agree to comply with this policy.

1.3 Regulatory Framework

Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq., including furnisher duties under §§ 1681s-2.
CFPB Regulation V (12 CFR Part 1022), implementing FCRA requirements for furnishers.
Fair and Accurate Credit Transactions Act (FACTA) amendments to FCRA.
Consumer Data Industry Association (CDIA) Metro 2 Format specifications and reporting guidelines.
Applicable state credit reporting laws and regulations, including state-specific dispute resolution requirements.

Policy Authority

This policy is issued under the authority of the Chief Compliance Officer and has been approved by the Executive Leadership Team. All amendments require approval through the Policy Governance Committee with appropriate documentation and communication to affected stakeholders.

2. Accuracy and Integrity of Furnished Information

HL Hunt is committed to furnishing information that is accurate, complete, and reflects the true status of consumer accounts. Maintaining data integrity is fundamental to our compliance obligations and our commitment to fair treatment of consumers.

2.1 Data Accuracy Standards

All consumer information shall be verified for accuracy through systematic validation procedures prior to transmission to any consumer reporting agency.
Data elements shall be cross-referenced against source systems of record to ensure consistency and correctness before furnishing.
Automated validation rules shall be implemented to detect and prevent common data errors including invalid date formats, out-of-range values, and logical inconsistencies.
Manual review processes shall supplement automated controls for high-risk data elements and exception conditions.

2.2 Data Completeness Requirements

All required Metro 2 data fields shall be populated with accurate information; optional fields shall be furnished when data is available and relevant.
Account information shall be reported in its entirety, including positive payment history, to provide CRAs with a complete picture of consumer credit behavior.
Missing or unavailable data elements shall be identified and addressed through established data remediation procedures prior to furnishing.
Partial or incomplete records shall not be transmitted unless explicitly permitted by Metro 2 specifications and documented exception protocols.

2.3 Data Currency and Timeliness

Consumer account information shall be updated and furnished to CRAs on a monthly reporting cycle, or more frequently as required by regulatory obligations or business needs.
Account status changes, including payments, delinquencies, charge-offs, and account closures, shall be reflected in the next scheduled reporting cycle following the event.
Corrections and updates resulting from dispute investigations shall be transmitted within the timeframes mandated by FCRA (generally within 30 days of dispute receipt).
Reporting schedules shall be documented and monitored to ensure consistent and timely data transmission.

2.4 Error Prevention and Detection

Pre-submission validation routines shall be executed to identify and quarantine records containing errors, duplications, or inconsistencies before transmission.
Exception reports shall be generated and reviewed by designated data quality personnel prior to each reporting cycle.
Root cause analysis shall be performed for systematic errors to identify process improvements and prevent recurrence.
Error rates shall be tracked and reported to management with corrective action plans for trends exceeding acceptable thresholds.

Accuracy Commitment

HL Hunt maintains a target data accuracy rate of 99.5% or higher for all furnished information. Accuracy metrics are monitored monthly and reported to the Compliance Committee. Deviations from target accuracy levels trigger immediate remediation protocols and management escalation.

3. Metro 2 Compliance

HL Hunt adheres to Metro 2 Format standards established by the Consumer Data Industry Association (CDIA) as the industry-standard format for furnishing consumer credit information to credit reporting agencies.

3.1 Format Specifications

All consumer data furnished to CRAs shall conform to the current Metro 2 Format specifications as published by the CDIA, including all mandatory and conditional data fields.
Data formatting shall adhere to Metro 2 character set requirements, field lengths, and positioning specifications without deviation.
Header, base, and trailer record structures shall be properly formatted and validated prior to each transmission.
Format updates published by CDIA shall be implemented within the timeframes specified in industry guidance, with appropriate testing and validation.

3.2 Reporting Codes and Status Indicators

Account status codes, payment rating codes, and special comment codes shall be applied accurately in accordance with Metro 2 definitions and business rules.
Code selection shall be based on documented criteria ensuring consistent application across all accounts and reporting periods.
Compliance Status codes shall be used appropriately to indicate accounts in dispute, bankruptcy, or other special conditions.
Code usage shall be audited regularly to ensure proper application and consistency with account characteristics.

3.3 Dispute Resolution per Metro 2 Standards

Dispute processing shall follow Metro 2 Automated Consumer Dispute Verification (ACDV) procedures for disputes received through CRA channels.
Response codes shall accurately reflect the outcome of dispute investigations (verified, updated, deleted) in accordance with Metro 2 specifications.
Corrected or updated information shall be transmitted using appropriate Metro 2 correction indicators and processes.
Direct dispute procedures shall comply with Metro 2 guidance for disputes received directly from consumers.

3.4 Technical Implementation

Data transmission methods shall comply with CRA technical specifications for secure file transfer, including encryption and authentication requirements.
File naming conventions, transmission schedules, and acknowledgment procedures shall conform to CRA and Metro 2 requirements.
System interfaces shall be maintained and tested to ensure reliable data transmission and receipt confirmation.
Technical documentation shall be maintained for all Metro 2 implementation specifications and customizations.

3.5 Training and Certification

Personnel responsible for Metro 2 reporting shall complete CDIA-approved training and maintain current knowledge of format specifications.
Annual recertification shall be required for all staff with Metro 2 reporting responsibilities.
Training records shall be maintained and made available for audit and compliance verification.
Updates to Metro 2 specifications shall be communicated to affected personnel with supplemental training as needed.

4. Consumer Dispute Investigation and Resolution

HL Hunt maintains comprehensive procedures for the fair, timely, and thorough investigation of consumer disputes regarding furnished information, in compliance with FCRA requirements and industry best practices.

4.1 Dispute Receipt and Intake

Disputes shall be accepted through multiple channels including CRA-forwarded ACDV notices, direct consumer correspondence, telephone inquiries, and electronic submissions.
All disputes shall be logged in the Dispute Management System within one (1) business day of receipt with assignment of unique tracking identifiers.
Dispute intake procedures shall capture all relevant information including consumer identification, disputed items, basis for dispute, and supporting documentation.
Acknowledgment of receipt shall be provided to consumers for direct disputes within five (5) business days.

4.2 Investigation Procedures

All disputes shall be investigated thoroughly by reviewing all relevant information, including information provided by the consumer and records maintained by the Company.
Investigation shall be completed within thirty (30) calendar days of receipt, or forty-five (45) days if the consumer provides additional information during the investigation period.
Investigators shall have access to source systems and documentation necessary to verify the accuracy of disputed information.
Investigation findings shall be documented with supporting evidence and rationale for conclusions reached.

4.3 Resolution and Reporting

Upon completion of investigation, disputed information shall be corrected, deleted, or verified as accurate based on investigation findings.
If information is found to be inaccurate or incomplete, corrections shall be reported to all CRAs to which the information was previously furnished.
Consumers shall be notified of investigation results within five (5) business days of completion, including a description of the procedure used and contact information for further inquiries.
For ACDV disputes, response shall be transmitted to the initiating CRA within the required timeframe using appropriate Metro 2 response codes.

Dispute Type	Source	Investigation Deadline	Response Requirement
ACDV Dispute	CRA-forwarded	30 days	Metro 2 ACDV response
Direct Dispute	Consumer direct	30 days (45 with add'l info)	Written notice to consumer
Fraud/Identity Theft	Consumer/CRA	30 days	Block or correction per FCRA
Systematic Error	Internal discovery	Prompt correction	Correction to all CRAs

4.4 Documentation and Record Retention

Complete records of all dispute investigations shall be maintained, including the dispute notice, investigation steps, evidence reviewed, and resolution determination.
Dispute records shall be retained for a minimum of five (5) years from the date of resolution, or longer if required by applicable state law or litigation hold.
Records shall be maintained in a manner that permits retrieval for regulatory examination, audit, and legal discovery purposes.
Dispute metrics and trend analysis shall be reported monthly to the Compliance Committee for monitoring and process improvement.

4.5 Frivolous or Irrelevant Disputes

Disputes determined to be frivolous or irrelevant based on FCRA criteria may be declined for investigation with appropriate notice to the consumer or CRA.
Frivolous dispute determinations shall be made by designated compliance personnel and documented with specific rationale.
Consumers shall be notified within five (5) business days of a frivolous determination, including the reasons for the determination and any information required to investigate.
Frivolous dispute criteria and determinations shall be reviewed quarterly to ensure consistent and appropriate application.

5. Periodic Reviews of Policies and Procedures

HL Hunt conducts systematic reviews of data furnishing policies and procedures to ensure continued regulatory compliance, operational effectiveness, and alignment with industry best practices.

5.1 Annual Policy Review

Comprehensive review of all data furnishing policies and procedures shall be conducted annually by the Compliance Department in coordination with affected business units.
Reviews shall assess policy alignment with current FCRA requirements, CFPB guidance, Metro 2 specifications, and industry best practices.
Findings and recommendations shall be documented and presented to the Policy Governance Committee for approval of necessary updates.
Policy revisions shall be communicated to all affected personnel with appropriate training on material changes.

5.2 Quarterly Accuracy Audits

Quarterly audits shall be conducted to assess the accuracy and completeness of data furnished to CRAs during the preceding period.
Audit methodology shall include statistical sampling of furnished records, comparison to source systems, and validation of Metro 2 format compliance.
Audit findings shall be documented with identified deficiencies, root cause analysis, and corrective action recommendations.
Audit results shall be reported to the Compliance Committee and Chief Compliance Officer within fifteen (15) business days of audit completion.

5.3 Regulatory Change Management

Regulatory developments affecting data furnishing obligations shall be monitored continuously through subscription services, industry associations, and legal counsel.
Impact assessments shall be conducted for new regulations or guidance within thirty (30) days of publication.
Policy and procedure updates required by regulatory changes shall be implemented within compliance deadlines established by the issuing authority.
Regulatory change tracking and implementation status shall be reported to the Compliance Committee monthly.

5.4 Continuous Improvement

Process improvement opportunities identified through audits, dispute trends, error analysis, and employee feedback shall be evaluated and prioritized for implementation.
Industry benchmarking shall be conducted annually to compare Company practices against peer organizations and identify enhancement opportunities.
Technology enhancements to improve accuracy, efficiency, and compliance shall be evaluated and implemented through the established change management process.
Improvement initiatives shall be tracked and reported with measurable outcomes to demonstrate continuous enhancement of data furnishing operations.

6. Quality Control Program

HL Hunt maintains a structured quality control program to ensure the accuracy, completeness, and integrity of all consumer information furnished to credit reporting agencies.

6.1 Pre-Submission Quality Checks

Automated validation routines shall be executed on all data files prior to submission to CRAs, checking for format compliance, data integrity, and business rule adherence.
Exception reports shall be generated for records failing validation, with quarantine procedures preventing transmission of defective data.
Designated quality control personnel shall review and disposition exception records prior to each reporting cycle.
Validation rule libraries shall be maintained and updated to address new error patterns and regulatory requirements.

6.2 Post-Submission Monitoring

CRA acknowledgment and rejection reports shall be reviewed within two (2) business days of receipt to identify and address rejected records.
Rejection root causes shall be analyzed and corrective measures implemented to prevent recurrence.
Rejection rates shall be tracked and reported monthly, with investigation triggered for rates exceeding established thresholds.
Consumer complaints and disputes shall be analyzed for patterns indicating systematic data quality issues.

6.3 Accuracy Testing Program

Monthly statistical sampling shall be conducted to verify accuracy of furnished data against source system records.
Sample sizes shall be determined using accepted statistical methodologies to achieve confidence levels of 95% or higher.
Testing results shall be documented with identified discrepancies investigated and corrected.
Accuracy metrics shall be trended over time to identify improvement or degradation requiring management attention.

6.4 Discrepancy Resolution

Identified discrepancies shall be classified by severity and impact, with resolution timeframes based on classification.
Critical discrepancies affecting consumer credit profiles shall be corrected and reported to CRAs within five (5) business days.
Root cause analysis shall be performed for all discrepancies to identify process improvements and prevent recurrence.
Discrepancy logs shall be maintained and reviewed monthly by the Quality Control Manager.

6.5 Quality Control Documentation

Complete records of quality control activities shall be maintained, including validation results, exception dispositions, testing outcomes, and corrective actions.
Quality control records shall be retained for a minimum of three (3) years and made available for audit and regulatory examination.
Monthly quality control reports shall be prepared and distributed to the Compliance Committee and affected business unit management.
Annual quality control program assessments shall evaluate program effectiveness and identify enhancement opportunities.

7. Training and Certification

HL Hunt ensures all personnel involved in data furnishing activities receive comprehensive training on regulatory requirements, Metro 2 standards, and Company policies and procedures.

7.1 Initial Training Requirements

All employees assigned to data furnishing roles shall complete comprehensive initial training before assuming job responsibilities.
Initial training curriculum shall include FCRA furnisher obligations, CFPB Regulation V requirements, Metro 2 format specifications, and Company policies and procedures.
Training shall include practical exercises and assessments to verify comprehension and ability to apply learned concepts.
Training completion shall be documented in employee records with certification of successful completion required before system access is granted.

7.2 Annual Recertification

All personnel with data furnishing responsibilities shall complete annual recertification training to maintain current knowledge of requirements and procedures.
Recertification training shall address regulatory updates, policy changes, and lessons learned from audits and incidents.
Employees failing to complete recertification within required timeframes shall have system access suspended until training is completed.
Recertification records shall be maintained and reported to management quarterly.

7.3 Specialized Training

Personnel with dispute investigation responsibilities shall receive specialized training on FCRA dispute handling requirements and investigation procedures.
Technical staff responsible for Metro 2 implementation shall complete CDIA-approved Metro 2 training and maintain current certification.
Supervisory personnel shall receive additional training on quality control, compliance monitoring, and escalation procedures.
Specialized training shall be refreshed when significant regulatory or procedural changes occur.

Training Type	Target Audience	Frequency	Duration
FCRA Furnisher Fundamentals	All furnishing personnel	Initial + Annual	4 hours
Metro 2 Format Specifications	Technical staff	Initial + Annual	8 hours
Dispute Investigation	Dispute handlers	Initial + Annual	6 hours
Quality Control Procedures	QC personnel	Initial + Semi-annual	4 hours
Data Security & Privacy	All personnel	Initial + Annual	2 hours

7.4 Third-Party Training Requirements

Third-party vendors and contractors performing data furnishing functions shall demonstrate that personnel have received equivalent training on applicable requirements.
Vendor training programs shall be reviewed and approved by HL Hunt Compliance Department prior to engagement.
Evidence of vendor training completion shall be maintained and verified annually.
Vendor personnel failing to meet training requirements shall be prohibited from performing data furnishing activities.

8. Vendor Management

Third-party vendors performing data furnishing functions on behalf of HL Hunt are subject to comprehensive oversight to ensure compliance with all applicable requirements and Company standards.

8.1 Vendor Selection and Due Diligence

Prospective vendors shall undergo comprehensive due diligence assessment including evaluation of compliance programs, data security controls, financial stability, and industry reputation.
Due diligence shall include review of vendor certifications (SOC 2, ISO 27001), independent audit reports, and regulatory examination history.
Vendors with material compliance deficiencies or adverse regulatory history shall not be engaged for data furnishing activities.
Due diligence findings shall be documented and approved by the Vendor Management Committee prior to engagement.

8.2 Contractual Requirements

Vendor contracts shall include explicit requirements for compliance with FCRA, CFPB regulations, Metro 2 standards, and HL Hunt policies.
Contracts shall specify data accuracy standards, dispute handling procedures, and service level agreements with measurable performance metrics.
Right to audit clauses shall be included permitting HL Hunt to examine vendor compliance and performance.
Breach notification, indemnification, and termination provisions shall address compliance failures and data incidents.

8.3 Ongoing Monitoring and Oversight

Vendor performance shall be monitored continuously against contractual SLAs and compliance requirements.
Quarterly performance reviews shall assess data accuracy, dispute handling timeliness, and compliance with Metro 2 specifications.
Annual on-site or remote audits shall verify vendor compliance with contractual requirements and applicable regulations.
Performance dashboards shall be maintained and reviewed monthly by the Vendor Relationship Manager.

8.4 Compliance Breach Response

Vendors shall be required to report any compliance breaches, data incidents, or regulatory inquiries to HL Hunt within twenty-four (24) hours of discovery.
Compliance breaches shall trigger immediate investigation and implementation of corrective measures.
Material or repeated breaches shall result in enhanced oversight, remediation requirements, or contract termination.
Breach incidents and resolutions shall be documented and reported to the Compliance Committee.

8.5 Vendor Termination Procedures

Termination procedures shall ensure orderly transition of data furnishing responsibilities with minimal disruption to reporting obligations.
Data return or destruction requirements shall be specified and verified upon termination.
Post-termination audits shall confirm vendor compliance with data handling and confidentiality obligations.
Termination decisions and rationale shall be documented and retained for compliance records.

9. FCRA Compliance

HL Hunt maintains comprehensive compliance with all provisions of the Fair Credit Reporting Act applicable to furnishers of consumer credit information.

9.1 Furnisher Duties Under FCRA § 1681s-2

Information shall be furnished only after implementing reasonable procedures to ensure maximum possible accuracy of the information.
Information shall not be furnished if the Company knows or has reasonable cause to believe the information is inaccurate.
Information previously furnished shall be corrected and updated promptly when determined to be incomplete or inaccurate.
Notice shall be provided to CRAs when accounts are closed by consumers, when consumers dispute accuracy directly, and when accounts are charged off or subject to other reportable events.

9.2 Duties Upon Notice of Dispute

Upon receipt of dispute notice from a CRA, the Company shall conduct a reasonable investigation with respect to the disputed information.
All relevant information provided by the CRA pursuant to FCRA § 1681i(a)(2) shall be reviewed and considered in the investigation.
Investigation results shall be reported to the CRA, including any corrections or deletions, and to all other CRAs if the information is found to be inaccurate.
If requested information cannot be verified, the information shall be deleted or modified as appropriate.

9.3 Direct Dispute Requirements

Procedures shall be maintained for receiving and processing disputes submitted directly by consumers (direct disputes) in accordance with CFPB Regulation V.
Direct disputes shall be investigated using the same standards and timeframes applicable to CRA-forwarded disputes.
Consumers shall be notified of investigation results and any changes made to their information as a result of the investigation.
Address and contact information for submitting direct disputes shall be provided to consumers upon request.

9.4 Identity Theft and Fraud Procedures

Procedures shall be maintained for responding to notifications that information may have resulted from identity theft.
Information shall be blocked from reporting upon receipt of appropriate identity theft report and victim identification.
Investigation shall be conducted to determine if reported accounts are fraudulent before resuming furnishing.
Coordination with law enforcement and CRAs shall be maintained for identity theft matters as required by FCRA.

9.5 Negative Information Notice Requirements

When negative information is furnished for the first time regarding an account, consumers shall be notified in accordance with FCRA § 1681s-2(a)(7).
Notice shall be provided before or within thirty (30) days after furnishing the negative information.
Notice content shall comply with FCRA and CFPB model notice requirements.
Notice delivery methods and documentation shall comply with applicable requirements.

Regulatory Enforcement

Violations of FCRA furnisher requirements may result in civil liability to consumers, enforcement actions by the CFPB, FTC, or state attorneys general, and reputational harm. The Company maintains comprehensive compliance programs to minimize regulatory risk and protect consumers.

10. Resource Planning and Staffing

HL Hunt maintains adequate staffing and resources to ensure effective data furnishing operations, timely dispute resolution, and robust compliance oversight.

10.1 Staffing Requirements

Staffing levels for data furnishing operations shall be based on volume analysis, dispute trends, and compliance requirements to ensure adequate capacity.
Staffing models shall account for seasonal variations, growth projections, and regulatory changes affecting workload.
Contingency staffing plans shall be maintained to address unexpected volume increases or staff unavailability.
Staffing adequacy shall be assessed quarterly with adjustments made as needed to maintain service levels.

10.2 Compliance Oversight Structure

Dedicated compliance personnel shall be assigned to oversee data furnishing activities, monitor regulatory developments, and coordinate examination activities.
A designated Furnisher Compliance Officer shall have overall responsibility for ensuring compliance with FCRA, CFPB regulations, and Metro 2 requirements.
Compliance staff shall be independent of business operations with direct reporting to the Chief Compliance Officer.
Compliance staffing shall be commensurate with the scope and complexity of data furnishing activities.

10.3 Dispute Resolution Capacity

Dispute investigation staffing shall be sufficient to ensure all disputes are investigated and resolved within FCRA-mandated timeframes.
Backlog monitoring shall be conducted daily with escalation procedures for volume exceeding capacity.
Cross-training shall ensure backup capacity for dispute investigation functions during peak periods or staff absences.
Dispute staffing metrics shall be tracked and reported weekly to operations management.

10.4 Technology and Automation

Technology solutions shall be implemented to enhance accuracy, efficiency, and compliance of data furnishing operations.
Automated validation, exception processing, and workflow management systems shall be utilized to reduce manual effort and error rates.
System enhancements shall be evaluated and prioritized based on compliance impact, efficiency gains, and cost-benefit analysis.
Technology investments shall be aligned with the Company's overall information technology strategy and governance processes.

10.5 Professional Development

Career development paths shall be established for data furnishing personnel to promote retention and build expertise.
Attendance at industry conferences, CDIA events, and professional development opportunities shall be supported and encouraged.
Succession planning shall ensure continuity of critical knowledge and capabilities.
Performance management shall incorporate compliance and quality metrics alongside productivity measures.

11. Enforcement and Compliance Monitoring

HL Hunt maintains robust enforcement mechanisms and monitoring programs to ensure adherence to data furnishing policies and regulatory requirements.

11.1 Compliance Monitoring Program

Ongoing monitoring activities shall be conducted to assess compliance with FCRA, CFPB regulations, Metro 2 standards, and Company policies.
Monitoring shall include transaction testing, quality control reviews, dispute handling audits, and policy adherence assessments.
Monitoring findings shall be documented with identified issues tracked to remediation.
Monthly compliance reports shall be prepared and distributed to the Compliance Committee and affected business unit management.

11.2 Employee Accountability

Employees are expected to comply fully with all data furnishing policies and procedures; non-compliance may result in disciplinary action.
Disciplinary measures shall be proportionate to the severity and frequency of violations and may include verbal warning, written warning, suspension, or termination.
Intentional violations, falsification of records, or actions causing consumer harm shall be treated as serious misconduct.
Disciplinary actions shall be documented in personnel files and reported to Human Resources.

11.3 Vendor Accountability

Vendors failing to meet contractual compliance standards shall be subject to corrective action including remediation plans, enhanced monitoring, or contract termination.
Material compliance breaches shall be escalated to the Vendor Management Committee and Chief Compliance Officer.
Vendor compliance performance shall be a factor in contract renewal and business allocation decisions.
Vendor accountability measures shall be documented and enforced consistently.

11.4 Internal Investigation Procedures

Allegations of policy violations or compliance failures shall be investigated promptly and thoroughly by appropriate personnel.
Investigations shall be conducted objectively with appropriate confidentiality protections.
Investigation findings shall be documented with recommendations for corrective action and process improvements.
Significant findings shall be reported to the Compliance Committee and, where required, to regulatory authorities.

11.5 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 and examination responses.
Regulatory examination findings shall be addressed through formal corrective action plans with progress tracked to completion.
Regulatory developments and enforcement trends shall be monitored and incorporated into compliance program enhancements.

Whistleblower Protection

Employees who report suspected violations in good faith are protected from retaliation. Reports may be submitted through the Ethics Hotline, directly to the Compliance Department, or through other established channels. Anonymous reporting options are available.

Commitment to Compliance and Consumer Protection

By implementing and adhering to this Data Furnisher Policy, HL Hunt ensures the accuracy, integrity, and compliance of all consumer information reported to credit reporting agencies. These standards reflect our commitment to fair treatment of consumers, regulatory compliance, and maintenance of trust with our business partners and stakeholders.

Questions regarding these policies should be directed to the Furnisher Compliance Officer or the Chief Compliance Officer. Policy exceptions require written approval from appropriate executive authority as defined in the Policy Governance Framework.

Last Reviewed: January 1, 2025 | Next Review: January 1, 2026 | Policy Owner: Chief Compliance Officer