Notice to Data Furnishers

The following applies with respect to all Services, and is incorporated into by reference and made a part of each individual Services Addendum set forth beneath this Notice to Data Furnishers.

All furnishers of consumer reports must comply with all applicable regulations, including regulations promulgated after this notice was first prescribed in 2004. Information about applicable regulations currently in effect can be found at the Consumer Financial Protection Bureau’s website: https://www.consumerfinance.gov/learnmore/. Kuiper OpCo, LLC’s (d/b/a SNH AI) provision of this Notice to Data Furnishers is not intended, and shall not be deemed or construed as, and SNH AI does not make and hereby expressly disclaims, any admission, agreement or representation of any kind that SNH AI is or is not a data furnisher, CRA, reseller, or any other type of FCRA-regulated entity. SNH AI is an AI software tool utilized by CRAs and other third-party FCRA-regulated entities on an independent basis to aid such organizations in the ordinary course of their respective businesses. You are strongly advised to seek independent legal counsel with respect to all duties and obligations imposed by or under the FCRA.

NOTICE TO FURNISHERS OF INFORMATION: OBLIGATIONS OF FURNISHERS UNDER THE FCRA

The federal Fair Credit Reporting Act (FCRA), 15 U.S.C. 1681-1681y, imposes responsibilities on all persons who furnish information to consumer reporting agencies (CRAs). These responsibilities are found in Section 623 of the FCRA, 15 U.S.C. 168ls-2. State law may impose additional requirements on furnishers. All furnishers of information to CRAs should become familiar with the applicable laws and may want to consult with their counsel to ensure that they are in compliance. The text of the FCRA is set forth in full at the Bureau of Consumer Financial Protection’s website at www.consumerfinance.gov A list of the sections of the FCRA cross-referenced to the U.S. Code is at the end of this document.

Section 623 imposes the following duties upon furnishers:

Accuracy Guidelines

The banking and credit union regulators and the CFPB will promulgate guidelines and regulations dealing with the accuracy of information provided to CRAs by furnishers. The regulations and guidelines issued by the CFPB will be available at www.consumerfinance.gov when they are issued. Section 623(e).

General Prohibition on Reporting Inaccurate Information

The FCRA prohibits information furnishers from providing information to a CRA that they know or have reasonable cause to believe is inaccurate. However, the furnisher is not subject to this general prohibition if it clearly and conspicuously specifies an address to which consumers may write to notify the furnisher that certain information is inaccurate. Sections 623(a)(1)(A) and (a)(1)(C).

Duty to Correct and Update Information

If at any time a person who regularly and in the ordinary course of business furnishes information to one or more CRAs determines that the information provided is not complete or accurate, the furnisher must promptly provide complete and accurate information to the CRA. In addition, the furnisher must notify all CRAs that received the information of any corrections and must thereafter report only the complete and accurate information. Sections 623(a)(2).

Duties After Notice of Dispute from Consumer

If a consumer notifies a furnisher, at an address specified for the furnisher for such notices, that specific information is inaccurate, and the information is, in fact, inaccurate, the furnisher must thereafter report the correct information to CRAs. Section 623(a)(1)(B).

If a consumer notifies a furnisher that the consumer disputes the completeness or accuracy of any information reported by the furnisher, the furnisher may not subsequently report that information to a CRA without providing notice of the dispute. Section 623(a)(3).

The federal banking and credit union regulators and the CFPB will issue regulations that will identify when an information furnisher must investigate a dispute made directly to the furnisher by a consumer.  Once these regulations are issued, furnishers must comply with them and complete an investigation within 30 days (or 45 days if the consumer later provides relevant additional infom1ation) unless the dispute is frivolous or irrelevant or comes from a “credit repair organization.” The CFPB regulations will be available at https://www.consumerfinance.gov/learnmore/. Section 623(a)(8).

Duties After Notice of Dispute from Consumer Reporting Agency.

If a CRA notifies a furnisher that a consumer disputes the completeness or accuracy of information provided by the furnisher, the furnisher has a duty to follow certain procedures. The furnisher must:

• Conduct an investigation and review all relevant information provided by the CRA, including information given to the CRA by Sections 623(b)(1)(A) and (b)(1)(B).

• Report the results to the CRA that referred the dispute, and, if the investigation establishes that the information was, in fact, incomplete or inaccurate, report the results to all CRAs to which the furnisher provided the information that compile and maintain files on a nationwide Section 623(b)(l)(C) and (b)(l)(D).

• Complete the above steps within 30 days from the date the CRA receives the dispute (or 45 days if the consumer later provides relevant additional information to the CRA). Section 623(b)(2)

• Promptly modify or delete the information or block its reporting. Section 623(b)(1)(E).

Duty to Report Voluntary Closing of Credit Accounts

If a consumer voluntarily closes a credit account, any person who regularly and in the ordinary course of business furnishes information to one or more CRAs must report this fact when it provides information to CRAs for the time period in which the account was closed.

Duty to Report Dates of Delinquencies

If a furnisher reports information concerning a delinquent account placed for collection, charged to profit or loss, or subject to any similar action, the furnisher must, within 90 days after reporting the information, provide the CRA with the month and the year of the commencement of the delinquency that immediately preceded the action, so that the agency will know how long to keep the information in the consumer’s file. Section 623(a)(5).

Any person, such as a debt collector, that has acquired or is responsible for collecting delinquent accounts and that reports information to CRAs may comply with the requirements of Section 623(a)(5) (until there is a consumer dispute) by reporting the same delinquency date previously reported by the creditor. If the creditor did not report this date, they may comply with the FCRA by establishing reasonable procedures to obtain and report delinquency dates, or, if a delinquency date cannot be reasonably obtained, by following reasonable procedures to ensure that the date reported precedes the date when the account was placed for collection, charged to profit or loss, or subjected to any similar action. Section 623(a)(5).

Duties of Financial Institutions When Reporting Negative Information

Financial institutions that furnish information to “nationwide” consumer reporting agencies, as defined in Section 603(p), must notify consumers in writing if they may furnish or have furnished negative information to a CRA. Section 623(a)(7). The Consumer Financial Protection Bureau has prescribed model disclosures, 12 CFR Part 222, App. B.

Duties When Furnishing Medical Information

A furnisher whose primary business is providing medical services, products, or devices (and such furnisher’s agents or assignees) is a medical information furnisher for the purposes of the FCRA and must notify all CRAs to which it reports of this fact. Section 623(a)(9). This notice will enable CRAs to comply with their duties under Section 604(g) when reporting medical information.

Duties When ID Theft Occurs

All furnishers must have in place reasonable procedures to respond to notifications from CRAs that information furnished is the result of identity theft, and to prevent refurnishing the information in the future. A furnisher may not furnish information that a consumer has identified as resulting from identity theft unless the furnisher subsequently knows or is informed by the consumer that the information is correct. Section 623(a)(6). If a furnisher learns that it has furnished inaccurate information due to identity theft, it must notify each consumer reporting agency of the correct information and must thereafter report only complete and accurate information. Section 623(a)(2). When any furnisher of information is notified pursuant to the procedures set forth in Section 605B that a debt has resulted from identity theft, the furnisher may not sell, transfer, or place for collection the debt except in certain limited circumstances. Section 615(f).

The Consumer Financial Protection Bureau website, www.consumer:finance.gov/learnmore, has more information about the FCRA.

Citations for FCRA sections in the U.S. Code, 15 U.S.C. § 1681 et seq.:

15 U.S.C. 1681 Section 615 15 U.S.C. 1681m

Section 603 15 U.S.C. 1681a Section 616 15 U.S.C. 1681n

Section 604 15 U.S.C. 1681b Section 617 15 U.S.C. 1681o

Section 605 15 U.S.C. 1681c Section 618 15 U.S.C. 1681p

Section 605A 15 U.S.C. 1681c-1 Section 619 15 U.S.C. 1681q

Section 605B 15 U.S.C. 1681c-2 Section 620 15 U.S.C. 1681r

Section 606 15 U.S.C. 1681d Section 621 15 U.S.C. 1681s

Section 607 15 U.S.C. 1681e Section 622 15 U.S.C. 1681s-1

Section 608 15 U.S.C. 1681f Section 623 15 U.S.C. 1681s-2

Section 609 15 U.S.C. 1681g Section 624 15 U.S.C. 1681t

Section 610 15 U.S.C. 1681h Section 625 15 U.S.C. 1681u

Section 611 15 U.S.C. 1681i Section 626 15 U.S.C. 1681v

Section 612 15 U.S.C. 1681j Section 627 15 U.S.C. 1681w

Section 613 15 U.S.C. 1681k Section 628 15 U.S.C. 1681x

Section 614 15 U.S.C. 1681l Section 629 15 U.S.C. 1681y

Description of Services

APPLICABLE TO ALL SERVICES ADDENDA: Notwithstanding anything to the contrary, Customer acknowledges and agrees that Customer’s receipt of all Services, and use of and access to the AI Technology in connection therewith, is undertaken solely and exclusively under Customer’s sole control and direction. Customer acknowledges and agrees that SNH AI is not, and will never be, an agent or representative of any kind or character for or on behalf of Customer, and that all actions taken and results generated through Customer’s use of the Services (including the AI Technology) are solely and exclusively the responsibility of Customer.

I.                    Services Addendum – General, Administrative, and Onboarding:

a.        Providing API documentation to Customer to assist with Customer’s completion of Customer’s side of the API and subsequent API integration

b.       Onboarding and configuration services to assist Customer with systems orientation, including collecting and implementing fax/email templates, implementing the criteria, rules systems, and policies dictated by Customer, enabling call forwarding/IVR integration, etc.

c.        Providing metering/usage and basic reporting with respect to Customer’s API usage within an administrative dashboard accessible to Customer.

d.       Providing assistance and consultation with respect to Customer’s evaluation of best use-cases for integrating the AI Technology into Customer’s workflows.

e.        Identifying outstanding AI Technology requirements in order to update and/or modify the API to support them (as needed).

II.                  Services Addendum – Verification Assistance: Facilitating AI Technology-assisted searches via API (applicant data, search data, & other data) with prescribed flags or parameters that determine how the AI Technology assists with administering the search. These services include providing for Customer’s use of and access to AI Technology to assist Customer with:

a.        Identifying if an employer/school uses a third party and deciding whether or not to utilize it;

b.       Making outbound email, fax, and voice verification attempts;

c.        Processing inbound verification responses;

d.       Determining and executing on the next best action to take to collect the data;

e.        Returning verified data; and

f.        Performing accreditation checks on schools.

III.                Services Addendum – Public Records Assistance: Providing Customer with access to AI Technology via API to aid Customer in Customer’s performance of identity and reportability checks of vendor and applicant data, including by providing confidence level estimates of matches and reportability based on criteria and rule systems determined and configured solely and exclusively by Customer at Customer’s sole discretion. Customer acknowledges and agrees that any and all confidence level estimates generated through Customer’s receipt of the Services (including use of and access to the AI Technology) are attributable solely and entirely to the criteria and rule systems promulgated and configured by Customer, and Customer assumes full and complete responsibility with respect thereto.