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V.SPECIAL PROCEDURES FOR EMPLOYEE INVESTIGATIONS Section 603(x)provides special procedures for investigations of suspected misconduct by an employee or for compliance with Federal, state or local laws and regulations or the rules of a self-regulatory organization,and compliance with written policies of the employer. These investigations are not treated as consumer reports so long as the employer or its agent complies with the procedures set forth in Section 603(x), and a summary describing the nature and scope of the inquiry is made to the employee if an adverse action is taken based on the investigation. VI.OBLIGATIONS OF USERS OF MEDICAL INFORMATION Section 604(g)limits the use of medical information obtained from consumer reporting agencies(other than payment information that appears in a coded form that does not identify the medical provider). If the information is to be used for an insurance transaction,the consumer must give consent to the user of the report or the information must be coded. If the report is to be used for employment purposes—or in connection with a credit transaction(except as provided in federal regulations)—the consumer must provide specific written consent and the medical information must be relevant. Any user who receives medical information shall not disclose the information to any other person(except where necessary to carry out the purpose for which the information was disclosed,or as permitted by statute,regulation,or order). VII.OBLIGATIONS OF USERS OF"PRESCREENED"LISTS The FCRA permits creditors and insurers to obtain limited consumer report information for use in connection with unsolicited offers of credit or insurance under certain circumstances.Sections 603(1),604(c),604(e),and 614(d). This practice is known as"prescreening" and typically involves obtaining from a CRA a list of consumers who meet certain pre-established criteria. If any person intends to use prescreened lists,that person must(1)before the offer is made, establish the criteria that will be relied upon to make the offer and to grant credit or insurance,and(2)maintain such criteria on file for a three-year period beginning on the date on which the offer is made to each consumer. In addition,any user must provide with each written solicitation a clear and conspicuous statement that: • Information contained in a consumer's CRA file was used in connection with the transaction. •The consumer received the offer because he or she satisfied the criteria for credit worthiness or insurability used to screen for the offer. •Credit or insurance may not be extended if,after the consumer responds,it is determined that the consumer does not meet the criteria used for screening or any applicable criteria bearing on credit worthiness or insurability, or the consumer does not furnish required collateral. • The consumer may prohibit the use of information in his or her file in connection with future prescreened offers of credit or insurance by contacting the notification system established by the CRA that provided the report. The statement must include the address and toll-free telephone number of the appropriate notification system. In addition,the CFPB has established the format,type size,and manner of the disclosure required by Section 615(d),with which users must comply. The relevant regulation is 12 CFR 1022.54. VIII.OBLIGATIONS OF RESELLERS A.Disclosure and Certification Requirements Section 607(e)requires any person who obtains a consumer report for resale to take the following steps: •Disclose the identity of the end-user to the source CRA. •Identify to the source CRA each permissible purpose for which the report will be furnished to the end-user. • Establish and follow reasonable procedures to ensure that reports are resold only for permissible purposes, including procedures to obtain: (1)the identify of all end-users; (2)certifications from all users of each purpose for which reports will be used;and (3)certifications that reports will not be used for any purpose other than the purpose(s)specified to the reseller. Resellers must make reasonable efforts to verify this information before selling the report. B.Reinvestigations by Resellers Under Section 611(f),if a consumer disputes the accuracy or completeness of information in a report prepared by a reseller,the reseller must determine whether this is a result of an action or omission on its part and,if so,correct or delete the information. If not,the reseller must send the dispute to the source CRA for reinvestigation. When any CRA notifies the reseller of the results of an investigation,the reseller must immediately convey the information to the consumer. DataQuest CSA_Rev:20180524-2{CAS1655106.DOCX;2/11336.020002/} Page 13 of 14