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Fair Credit Reporting Act (FCRA) Policy

 

Effective Date: September 1, 2024

Policy Title: FCRA Credit Reporting Policy and Procedures
Responsible Party: Compliance Officer, April Wallace
Business Address: Seacoast Financial, LLC – 103 Regency Commons Dr., Greer, SC 29650-5210
Contact Phone: (864) 874-6100

Purpose

This policy aims to ensure compliance with the Fair Credit Reporting Act (FCRA) and related regulations in all credit reporting activities conducted by Seacoast Financial, LLC. The policy outlines the procedures for accurate reporting, consumer dispute handling, and record retention to protect consumer rights and maintain regulatory compliance.

Scope

This policy applies to all employees, agents, and third-party service providers involved in credit reporting activities on behalf of Seacoast Financial, LLC. The policy covers:

  • Reporting information to consumer reporting agencies (CRAs).
  • Responding to consumer disputes.
  • Maintaining and safeguarding consumer data.

Policy Statement

Seacoast Financial, LLC is committed to:

  • Providing accurate and complete information to CRAs.
  • Investigating and resolving disputes promptly and efficiently.
  • Safeguarding consumer information to prevent unauthorized access or misuse.
  • Complying with all FCRA requirements to protect consumer rights.

Definitions

Consumer Reporting Agency (CRA): An entity that collects and provides consumer credit information.
Furnisher: A person or entity that provides information to a CRA.
Consumer Dispute: A challenge a consumer raises regarding the accuracy of their credit report.

Procedures

1. Furnishing Accurate Information

  • Seacoast Financial, LLC will furnish accurate, complete, and up-to-date information to CRAs.
  • Employees must verify the accuracy of information before submitting it to a CRA.
  • If errors are identified, corrective action must be taken immediately to rectify the misinformation.

2. Handling Consumer Disputes

  • Acknowledgment: Upon receiving a consumer dispute, Seacoast Financial, LLC will acknowledge receipt within five (5) business days.
  • Investigation: The Compliance Officer, April Wallace, or her designee will investigate the dispute within 30 days (or 45 days if additional information is provided by the consumer).
    • Access relevant records to verify the disputed information.
    • Coordinate with the CRA and the consumer as needed.
  • Resolution:
    • If the dispute is valid, update the information with the CRA promptly.
    • If the information is accurate, inform the consumer and CRA of the findings.
  • Notification: Notify the consumer of the results of the investigation in writing within five (5) business days of resolution.

3. Consumer Data Safeguarding

  • Access to consumer data will be restricted to authorized personnel only.
  • Physical and electronic records will be stored securely.
  • Disposal of consumer data will comply with applicable laws to ensure complete destruction of sensitive information.

4. Record Retention

  • Maintain all records related to credit reporting and disputes for at least five (5) years.
  • Records must include:
    • Consumer disputes and communications.
    • Investigative actions and resolutions.
    • Correspondence with CRAs.

5. Monitoring and Auditing

  • Conduct regular audits to ensure compliance with FCRA requirements.
  • Document and address any deficiencies identified during audits.
  • Provide training to employees on FCRA compliance annually or as needed.

6. Compliance with Adverse Action Requirements

  • If adverse action is taken based on a consumer report, Seacoast Financial, LLC will provide the consumer notice either before or within 30 days, including:
    • A copy of the report was used.
    • Contact information for the CRA.
    • A summary of their rights under the FCRA.

Employee Responsibilities

  • Employees must familiarize themselves with this policy and FCRA requirements.
  • Report any suspected FCRA violations to the Compliance Officer immediately.
  • Participate in training and updates as required.

Compliance Officer Responsibilities

  • Oversee implementation and enforcement of this policy.
  • Respond to consumer disputes and ensure timely resolution.
  • Conduct periodic reviews of credit reporting activities.
  • Report compliance updates to senior management as needed.

Policy Violations

Violations of this policy may result in disciplinary action, including termination, and may expose Seacoast Financial, LLC to legal liability. Employees are required to report any suspected violations to the Compliance Officer.

Approval and Review

This policy will be reviewed annually and updated as necessary to ensure ongoing compliance with FCRA regulations.

Contact Information
For questions about this policy, please contact:
April Wallace
Compliance Officer
Seacoast Financial, LLC
Phone: (864) 874-6100

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