Compliance & Data Practices

Last Updated: November 15, 2025

Designed to meet the Fair Credit Reporting Act (FCRA) §623, 12 CFR 1022.42 (Accuracy & Integrity of Furnished Information), and Experian’s Data Furnisher Policies & Procedures, this framework ensures trustworthy data practices. If approved, we’ll furnish information in Metro 2® format and handle indirect disputes through e-OSCAR® (marks of their respective owners; no affiliation or endorsement implied).

1) Purpose & Scope

• Deliver precise, complete, timely, and reliable information to support fair credit reporting.
• Conduct thorough investigations and provide prompt resolutions for disputes.
• Uphold robust security, privacy, and oversight tailored to data sensitivity and scale.

2) Governance & Accountability

• Compliance Officer: Leads policy development, staff training, regular audits, dispute management, and coordination with CRAs.
• Change Management: Version control for policies, Metro 2 mappings, systems, and access permissions.
• Management Reporting: Monthly KPIs covering reject/error rates, dispute TAT, and corrective actions.

3) Accuracy & Integrity Program (12 CFR 1022.42)

• Comprehensive Procedures: SOPs for onboarding, verification, furnishing, corrections, and updates.
• Ongoing Evaluation: Annual review or upon significant product/system/regulatory change.
• Proactive Monitoring: Reject/error alerts, exception handling, post-submission sampling, and rapid remediation.

4) Eligibility, Verification & Consumer Notice

• Furnishing only with a legitimate relationship and permissible purpose under FCRA.
• KYC/KYB verification; SSN/EIN collected only when essential for matching and permitted by law.
• See our Reporting Policy for eligibility, what may be reported, and consumer rights.

5) Data Quality & Metro 2® Controls

6) Information Security

• Access Control: RBAC, least-privilege, MFA for sensitive actions, quarterly access reviews.
• Encryption: TLS for data in transit; secure storage for credentials/identifiers.
• Audit Logs: Retained for admin actions, submissions, and disputes per retention policy.
• Vendor Management: Security due diligence, NDAs, and documented data-flow mapping.

7) Furnishing Cadence & Timeliness

• Reliable monthly schedule (or as directed by Experian) once approved.
• Prompt corrections via AUD or updated Metro 2 files when errors are identified.
• Furnishing suspended if accuracy cannot be confidently verified.

8) Disputes & Corrections

• Identity-Theft Handling: Upon valid reports, we block reporting and notify CRAs per FCRA 605B.
• Consumer Guidance: Clear instructions for dispute filing and obtaining free CRA reports.

9) Training & Awareness

• Mandatory onboarding + annual refreshers on FCRA/Reg V, Experian guidelines, Metro 2, disputes, and security.
• Role-specific playbooks for data prep, submissions, and e-OSCAR workflows.

10) Record Retention & Audits

• Schedules for furnish files, reports, dispute records, communications, and logs.
• Regular QA sampling and independent audits; findings tracked to closure.

11) Business Continuity & Incident Response

• Continuity plan with defined recovery objectives (RTO/RPO) for critical systems/processes.
• Incident playbook for detection, containment, impact assessment, notifications, and lessons learned.

12) Experian Requirements → Our Controls (At-a-Glance)

Experian asks for…	Granvia control / artifact
Written accuracy & integrity program (1022.42)	Formal program + SOPs (validation, furnishing, disputes, corrections) with annual review sign-offs.
Reasonable dispute investigations & timely responses	Daily e-OSCAR queue, 30-day clock tracking, templates, evidence checklist, AUD corrections.
Security & access management	RBAC, MFA, encryption, quarterly access recerts, vendor due diligence, audit logging.
Metro 2 formatting and data quality	Mapping specs, pre-furnish validators, reject/error handling, DOFD/charge-off safeguards.
Clear consumer contact & dispute channel	Mailing address & disputes@granviagroupllc.com; instructions here and in Reporting Policy.
Change management & monitoring	Version control, KPI dashboard (rejects, errors, dispute TAT), quarterly management review.

13) Related Policies

• Reporting Policy
• Eligibility & Verification
• Member Agreement
• Security Overview
• Privacy Policy
• Your FCRA Rights