Fair Credit Reporting Act (FCRA) Compliance

Federal Law Compliance

Optimum Financial Services LLC is committed to full compliance with the Fair Credit Reporting Act (15 U.S.C. §1681 et seq.) and all applicable federal and state consumer protection laws.

Effective Date: January 1, 2025 | Version 4.0

1. FCRA OVERVIEW AND APPLICABILITY

1.1 Purpose and Scope

The Fair Credit Reporting Act (FCRA) promotes accuracy, fairness, and privacy of information in the files of consumer reporting agencies. This notice explains your rights under the FCRA and how Optimum Financial Services complies with these federal requirements.

1.2 Definitions Under FCRA

Consumer Report
Any written, oral, or other communication of information by a consumer reporting agency bearing on creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living.
Consumer Reporting Agency (CRA)
Any person which, for monetary fees, dues, or on a cooperative nonprofit basis, regularly engages in the practice of assembling or evaluating consumer credit information.
Adverse Action
A denial or revocation of credit, a change in the terms of an existing credit arrangement, or a refusal to grant credit in substantially the amount or on substantially the terms requested.

2. YOUR RIGHTS UNDER THE FCRA

2.1 Access to Your Credit Information

Free Annual Credit Reports

You are entitled to a free copy of your credit report from each of the three major credit bureaus once every 12 months.

Authorized Source: www.annualcreditreport.com

Phone: 1-877-322-8228

Mail: Annual Credit Report Request Service, P.O. Box 105281, Atlanta, GA 30348-5281

2.2 Additional Free Reports

You may also obtain a free credit report if:

  • You are unemployed and plan to look for employment within 60 days
  • You are on welfare
  • Your report is inaccurate because of fraud, including identity theft
  • You have been denied credit, employment, or insurance within the past 60 days
  • You are a victim of identity theft and place a fraud alert in your file

2.3 Dispute Rights

Disputing Inaccurate Information

If you find errors in your credit report, you have the right to dispute the information with both the credit reporting agency and the information furnisher (such as Optimum).

  • • Credit bureaus must investigate disputes within 30 days (45 days if additional information is provided)
  • • Inaccurate or unverifiable information must be corrected or deleted
  • • You must be notified of the results of the investigation
  • • Corrected reports must be sent to anyone who received your report in the past 6 months

3. OPTIMUM'S FCRA COMPLIANCE PRACTICES

3.1 Credit Reporting Procedures

Information TypeReporting FrequencyRetention Period
Payment HistoryMonthly7 years from first delinquency
Account StatusMonthly10 years from account closure
Credit Limit/High BalanceMonthly10 years from account closure
Charge-offsUpon occurrence7 years from charge-off date

3.2 Data Accuracy and Quality Control

  • Automated Data Validation: All reported data undergoes systematic accuracy checks
  • Monthly Reconciliation: Account information verified against internal records
  • Dispute Investigation: Dedicated team for handling consumer disputes within required timeframes
  • Staff Training: Regular FCRA compliance training for all personnel handling consumer data
  • Third-Party Audits: Annual compliance audits by independent firms

4. ADVERSE ACTION PROCEDURES

4.1 Pre-Adverse Action Notice

Before taking adverse action based on information in a consumer report, we will provide you with:

  • A copy of the consumer report we relied upon
  • A written description of your rights under the FCRA
  • Reasonable time to review the report and dispute any inaccuracies

4.2 Adverse Action Notice

Required Disclosures

If we take adverse action, we will provide written notice containing:

  • • The specific action taken
  • • Name, address, and phone number of the consumer reporting agency
  • • Statement that the CRA did not make the decision
  • • Your right to obtain a free copy of your credit report within 60 days
  • • Your right to dispute the accuracy or completeness of information

5. IDENTITY THEFT PROTECTION

5.1 Fraud Alerts

Initial Fraud Alert

90-day alert for suspected identity theft

Extended Fraud Alert

7-year alert for identity theft victims

Active Duty Alert

1-year alert for military personnel

5.2 Security Freeze

You have the right to place a security freeze on your credit report, which restricts access to your credit report without your consent. Security freezes are free for all consumers.

6. DISPUTE RESOLUTION PROCESS

6.1 How to Dispute Information

Contact Methods

Online Dispute Portal

www.optimumcard.com/dispute

Phone

1-800-OPTIMUM (1-800-678-4686), Option 3

Mail

Optimum Financial Services LLC
FCRA Dispute Department
P.O. Box 54321
New York, NY 10001

6.2 Investigation Timeline

TimeframeActionCommunication
Within 5 daysAcknowledge receipt of disputeEmail/mail confirmation
Within 30 daysComplete investigationResults notification
Within 5 days of completionReport corrections to CRAsConfirmation to consumer

7. CREDIT BUREAU CONTACT INFORMATION

Experian

P.O. Box 4000

Allen, TX 75013

1-888-397-3742

www.experian.com

Equifax

P.O. Box 740241

Atlanta, GA 30374

1-800-685-1111

www.equifax.com

TransUnion

P.O. Box 1000

Chester, PA 19016

1-800-916-8800

www.transunion.com

8. REGULATORY OVERSIGHT

8.1 Federal Agencies

FCRA compliance is overseen by multiple federal agencies depending on the type of entity:

  • Consumer Financial Protection Bureau (CFPB): Primary enforcement for most consumer financial services
  • Federal Trade Commission (FTC): Enforcement for non-bank entities
  • Federal Deposit Insurance Corporation (FDIC): State-chartered banks
  • Office of the Comptroller of the Currency (OCC): National banks

8.2 Filing Complaints

Consumer Financial Protection Bureau

Website: www.consumerfinance.gov/complaint

Phone: 1-855-411-2372

TTY: 1-855-729-2372

Mail: Consumer Financial Protection Bureau, P.O. Box 4503, Iowa City, IA 52244

Optimum FCRA Compliance Contact

FCRA Compliance Officer: compliance@optimumcard.com

Phone: 1-800-OPTIMUM (1-800-678-4686), Option 9

Mailing Address:

Optimum Financial Services LLC

FCRA Compliance Department

P.O. Box 54321

New York, NY 10001

Document Version: 4.0 | Last Updated: January 1, 2025 |Effective Date: January 1, 2025 | Next Review: January 1, 2026