The vast majority of recent FCRA related class action law suits, and there are MANY, claim Authorization/Disclosure violations or non-adherence to Adverse Action Notification regulations.
The Class Action litigation alleges Authorizations/Disclosures are non-compliant, in part, because Companies insert “extraneous information” within the body of the Authorizations (e.g. waivers, acknowledgments, etc.).
POE requested and received guidance from the DC Law Office of Arnall, Golden & Gregory, LLP, in revising the Authorizations & Disclosures that we recommend our clients use for Resident Screening, Employment Screening and Volunteer Screening. These are now available for you to review with your Legal Team and, if your counsel agrees, we recommend that our clients begin utilizing the revised Authorizations and Disclosures, immediately.
In conjunction with the revised documents, it’s time to initiate a round of Compliance Program Committee (CPC) meetings. We want to work with our clients to address all aspects of the screening process, specifically compliance with the FCRA as well as the other laws and regulations imposed by federal, state and local governments.
POE’s Compliance Manager, Kelsie Nelson, is reaching out to you, to schedule these meetings during which we will evaluate, review and update compliance matters, such as Red Flag Regulations, Resident/Employee/Volunteer Selection Criteria, FCRA Compliance, Ban-the-Box, Criminal Record Tiers & Matrices and more. Please feel free to contact Kelsie, regarding any issues that may arise.
Kelsie, Howard, and our entire POEknows Team look forward to our CPC Meetings with you.