Adverse-action responsibilities and notice delivery

Assign responsibility before a decision

1. 1Identify whether the report is used for employment or housing, which information influences the proposed decision and which local rules apply.
2. 2Identify the reporting company from the actual report and assign a customer reviewer to notices and applicant responses.
3. 3Confirm who prepares and sends each document, which delivery channels are supported, how delivery problems are surfaced and how records are retained under approved policy.
4. 4If a postal or other notice service is requested, verify its account availability and scope. Ordering a service is not proof that a notice was sent or received.

Employment notice sequence

• Before final employment adverse action, provide the consumer report and the current CFPB Summary of Rights. Allow a meaningful opportunity to review and respond, considering applicable local requirements.
• There is no universal federal five-business-day waiting period. Confirm the decision timetable with your compliance owner.
• If proceeding, provide the required final notice with the reporting company's name, address and phone; explain it did not make the decision and cannot explain it, and state dispute and free-report rights, including the 60-day request period.
• Review corrections and relevant individual context; do not treat a pending or disputed entry as automatic disqualification.

Housing notices are different

• Report-influenced denial, a co-signer requirement, higher rent, higher security deposit or other less favorable terms can be adverse action.
• Give the applicable notice identifying the reporting company's name, address and phone, stating it did not make the decision and cannot explain it, and explaining dispute and free-report rights, including requesting a free report within 60 days.
• If a credit score is used in the adverse decision, provide the additional score disclosures: score, possible range, key adverse factors, creation date and the name of the person or entity supplying it.
• Do not assume the federal employment pre-adverse sequence applies to housing. State/local rules and particular housing programs may add duties; consult the FTC landlord guidance and qualified advice.

Delivery failures and records

• Verify the recipient and approved channel before sending; prevent report copies being sent to another applicant or household member.
• Check the available delivery status or confirmation rather than assuming that generation equals sending. The account's actual tracking capabilities must be confirmed.
• If a message bounces, an address is wrong, or delivery is uncertain, alert the responsible reviewer and obtain compliance advice on correction and timing before finalizing the decision.
• Retain the decision basis, document versions, send dates, recipient/channel and available delivery evidence under your approved policy and applicable law. No universal retention period is specified here.

When an applicant disputes the report

• Direct accuracy disputes to the issuer's verified secure process; do not collect SSNs or evidence through ordinary email.
• The decision-maker should coordinate its response opportunity and applicable timetable with accuracy review; neither a dispute nor a support message establishes an automatic pause.
• Confirm whether a corrected report was issued and whether notices or the decision require further review. The issuer's correction is not itself a decision appeal outcome.

FTC employer guidance

FTC landlord guidance

Current Summary of Rights

Related guidance