Steadworth Fair Credit Reporting Act (FCRA) Policy

I. Introduction and Purpose

Steadworth, LLC ("Steadworth") is committed to complying with the Fair Credit Reporting Act ("FCRA") and its implementing regulations (Regulation V) to protect the privacy and accuracy of consumer credit information. This Policy outlines Steadworth's procedures for obtaining and using consumer reports and preventing identity theft.

II. Policy Statement

Steadworth will comply with all applicable provisions of FCRA and Regulation V, including:

• Obtaining consumer reports only for permissible purposes.

• Providing required disclosures to consumers.

• Ensuring the accuracy and integrity of information furnished to consumer reporting agencies.

• Protecting consumer information from identity theft.
  
  

III. Scope

This Policy applies to all Steadworth employees, officers, directors, and agents involved in any activity that involves consumer reports or consumer information.

IV. Permissible Purposes for Obtaining Consumer Reports

Steadworth will only obtain consumer reports for permissible purposes under the FCRA, which include:

• Evaluating an application for credit.

• Reviewing an existing credit account.

• Collecting on a debt.

• Detecting and preventing fraud.
  
  

V. Consumer Disclosures

Steadworth will provide consumers with the following disclosures as required by the FCRA:

• Disclosure of Adverse Action: If Steadworth takes adverse action against a consumer based on information in a consumer report, the consumer will be provided with a notice that includes the name and contact information of the consumer reporting agency that provided the report, the consumer's credit score, and the key factors that adversely affected the credit score.
  
  

VI. Identity Theft Prevention

Steadworth will implement a program to detect, prevent, and mitigate identity theft in connection with its Covered Accounts. This program will include procedures for identifying and verifying the identity of consumers, monitoring transactions for suspicious activity, and responding to suspected incidents of identity theft.

VII. Responsibilities

A. Compliance Officer:

• The Compliance Officer is responsible for overseeing and implementing this Policy.

• This includes developing and maintaining procedures, providing training to employees, and monitoring compliance with FCRA and Regulation V.
  
  

B. All Employees:

• All employees are responsible for complying with this Policy and reporting any potential violations to the Compliance Officer.
  
  

VIII. Training

Steadworth will provide regular training to its employees on FCRA compliance. This training will cover topics such as permissible purposes for obtaining consumer reports, consumer disclosure requirements, and identity theft prevention.

IX. Review and Revision

This Policy will be reviewed and revised periodically to ensure that it remains current and effective.

X. Conclusion

Steadworth is committed to protecting the privacy and accuracy of consumer credit information and complying with all applicable provisions of the FCRA. This Policy is intended to ensure that all employees are aware of their obligations under the FCRA and that Steadworth conducts its business in a compliant manner.

XI. Contact

Any questions or concerns regarding this Policy should be directed to the Compliance Officer at contact@steadworth.com

Please note: This Policy is intended to supplement, not replace, any other applicable Steadworth policies or procedures.