WRITTEN FILE DISCLOSURE OF CONSUMER CREDIT INFORMATION The following information is contained in the file on you at Date If you dispute any of the information in this disclosure, please write or call us, pointing out the disputed information and advising us what you believe to be the correct information. If any additions or corrections result from our reverification, or if record of your dispute is to be added to the file, notification will be sent to any firms you designate who have received a report on you in the past 6 months for credit purposes (or last 2 years for employment purposes). Subscribers who have received reports during the past six months (or two years if reports were for employment purposes): If the record contains reports from other credit bureaus, items of public record or other information, the details will appear on the reverse side. FORM 315-A Member Associated Credit Bureaus, Inc. PRINTED IN USA 4/77 Column indicating Method of Reporting A stands for Automated (computerized) records of reference furnishing information M is for non-computerized, or Manual records systems. Note A $10 - means $10 payments on a Revolving account 1 $75 - means $75 payments on an installment account Formerly, a numerical system was used by creditors to describe the usual manner of payment, 0 - Too new to rate, approved but not used 1 - Pays (or paid) within 30 days of billing, pays accounts as agreed 2 - Pays (or paid) in more that 30 days, but not more than 60 days, or not more than one 3- Pays (or paid) in more than 60 days, but not more than 90 days, or two payments past due payments past due 5. Account is a least 120 days overdue, but is not yet rated 19′′ 7 - Making regular payments under Wage Earner Plan of Bankruptcy Act, or similar arrangement Repossession (indicate if it is a voluntary return of merchandise by the customer) 9. Bad debit, or account placed for collection, or customer left, with no forwarding address Column headed Remarks These abbreviations may be used by creditors to explain unusual circumstances The credit reporting industry has long recog. nized the need for security measures to protect the integrity of the data contained in credit bureau files Each credit bureau has developed over the years a se urity program tailored to its own nis Deperuing i pon the bureau's experience, the security systems range from complex automated systems to very simple precautions to prevent tampering with credit records. Although a bureau may have a security program, it is becoming increasingly necessary that such programs be constantly updated to provide batter protection and at the same time to be ⚫st standardized throughou the sdu trư different operating environments will permit The procedures outlined below are intended to set out minimum security procedures which are required of ail ACB member cradit bureaus. More stringent methods which may be incorperated into a given credit bureau's system on an optional basis also are included. Organization for Security "A credit reporting agency, whether manual or Butomated must establish within its organizational structure the staff to insure that security measures are carried out properly *The staff may be a single individual who spends only a portion of his or her time handling all of the bureau's security measures or it may be a large group of people headed by a corporate officer in charge of a complex security system In either case, it is important that the function of securing files be properly staffed and that the people involved in security have full authority to carry out the responsibility asd to them Management should at all times exercise its responsibility to follow up closely and gree full support to the security function The work of the security group will be simplified greatly if bureau management will deperding upon the size and complex ty of the particular bu reau create a separation of functions carried out by an employee so that one person is not responsible. as an example for both doing the work and also authorizing it. This makes it more difficult for one person to tamper with a record by forcing, to some extent, collusion with another person It is recognized that in smaller operations such a separation of duties cannot be readily accomplished because of the small number of people involved in such cases, a greater degree of vigilance, closer supervision and more chacking of what is being done will be required of all supervisory or management personnel It will be seen in the pages to follow that security touches almost all aspects of credit bureau operations. Whether these functions are handled by one person or many, they are all important from a security standpoint It is important that the whole subject of security be considered not in the sense of what has or has not hij grad but of what can happen if this is cuna leaca bi reau will under, and the need for adopting measures which protect the accuracy of information that is so vital to the credit granting process Physical Security *Periodically review the physical security setup of the credit bureau building and office If you do not occupy your own building, be aware of and alert to the kinds of businesses and types of tenants who share the building with you if, in your opinion, certain tenants are undesirable or highsecurity risks, consider what measures may be taken to minimize the risk *Review the type locks now in use Get an ap praisal from a reliable locksmith if in doubt and resolve to afford locks which provide reasonable security Consider changing locks periodically especially upon the departure from your organization of employees who may be doubtful security risks Non reproducible keys. 'pick proof locks and burglar alarm systems are available and should be considered to strengthen the security of the file area Investigate the feasibility of augmenting exterior lighting of building and parking lot to reduce possi bility of break ins *Macitan controls on tha d fetation of kays and be sure that keys are dist. „buted on an as need bass only Be sure to retrieve the keys when an employee entrusted with their pussession leaves your employment *Physical access to the files of the credit bureau *Required A. A signed application which must conform to government regulations and guidelines is required. B. Application content: 1. Employment record Dues must be shown, and they should be accurate. b. Any time period not accounted for on the application should be inquired about as well as the reasons for any time shown as unemployed. (People frequently "forget" to list an unfavorable employment experience.) c. The applicant's reason for leaving past (1) Explore the applicant's attitude. (3) Determine if there was general (4) Decide if the applicant was fair with his former employer. 2. Educational background a. Application should call for names and dates. Addresses should be furnished, so written confirmation may be obtained. 3. Personal references a. The application should provide space for personal references. (1) Name, address, occupation and number of years known. (This information should be complete for each reference.) 4. Conviction record *Required a. The application should ask the question "Have you ever been convicted of a felony? If yes, give details." 1. Educational verification by mail a. New employee fills out two copies of an b. The following information is requested: (4) If student did not graduate, his reason (5) Any additional comments that might be helpful. B. Explanation of the Fair Credit Reporting Act and other induction procedures: 1. Confidential nature of the credit bureau's records. 2. Penalties for violation of FCRA and of company policies. 3. Credit bureau's enforcement policies and practices. *Required |