Compliance and Reporting Policy

Effective Date: April 10, 2026

This Compliance and Reporting Policy establishes the standards, procedures, and obligations governing TwelveFold Data Group LLC’s operations as a data furnisher reporting consumer and commercial account information to consumer reporting agencies (CRAs) in accordance with the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681s-2.

1. Purpose

The purpose of this policy is to ensure that TwelveFold Data Group LLC fulfills all legal and regulatory obligations as a data furnisher, maintains the highest standards of data accuracy and consumer protection, and operates in full compliance with all applicable federal and state laws governing credit reporting.

2. Regulatory Framework

TwelveFold Data Group LLC operates in compliance with the following federal regulations:

Fair Credit Reporting Act (FCRA) — 15 U.S.C. § 1681 et seq.
Fair Debt Collection Practices Act (FDCPA) — 15 U.S.C. § 1692 et seq.
Gramm-Leach-Bliley Act (GLBA) — 15 U.S.C. § 6801 et seq.
FTC Red Flags Rule — 16 C.F.R. Part 681
Metro 2 Format Standards — Credit Reporting Resource Guide (CRRG)
Applicable state consumer protection and privacy laws

3. Full-File Reporting Commitment

TwelveFold Data Group LLC is committed to full-file reporting. We report 100% of all open accounts on a fixed monthly schedule without exception. This requirement applies to all accounts including those that are current, delinquent, and charged-off. Selective reporting — the practice of reporting only favorable or current accounts — is strictly prohibited under this policy and inconsistent with CRA requirements. All data submitted must be 100% accurate, verifiable, and formatted in strict Metro 2 compliance.

4. Monthly Reporting Schedule

Data submissions to Equifax, Experian, and TransUnion occur on a fixed date each calendar month. All submissions include the complete portfolio of active accounts. No account is omitted from reporting without documented justification. Consistency of reporting is a non-negotiable compliance requirement. Failure to report on schedule constitutes non-compliance under FCRA Section 623.

5. Data Accuracy and Validation

Prior to every monthly submission all account-level data undergoes multi-point validation against Metro 2 format standards. Validation checks include field completeness, code accuracy, date consistency, and format compliance. Any errors identified during validation are corrected before transmission. A Quality Assurance log is maintained for every submission cycle documenting accounts reported, errors found and corrected, and submission confirmation.

6. Consumer Dispute Handling — 30-Day Timeline — FCRA Section 623(b)

TwelveFold Data Group LLC handles all consumer disputes in strict compliance with FCRA Section 623(b) obligations. Our mandatory dispute resolution timeline is as follows:

Day 0 — Dispute received via e-OSCAR or direct correspondence. Logged with case number assigned.
Days 0–2 — Consumer identity verified against account records.
Days 2–15 — Full internal investigation conducted. All relevant records reviewed including signed agreements, payment history, and account statements.
Days 15–25 — Resolution determined. Data corrected if inaccurate, verified if accurate, or deleted if unverifiable. All actions logged.
By Day 30 — Findings submitted to CRA via e-OSCAR. Written notice sent to consumer. No exceptions to this deadline are permitted.
Ongoing — All cases added to monthly Quality Assurance review log for trend analysis.

7. Permissible Purpose

We collect and report consumer and commercial account data solely for purposes permitted under the FCRA. Written authorization is obtained from every client prior to reporting. Records of all consent authorizations are maintained for a minimum of five years from the date of last report. Access to consumer data is restricted to authorized personnel with a documented permissible purpose.

8. Data Security and GLBA Compliance

All consumer and client data is protected by our written Information Security Program maintained in accordance with the GLBA Safeguards Rule. Our security infrastructure includes end-to-end encryption, role-based access controls, multi-factor authentication, weekly system backups, quarterly access reviews, and annual security assessments. All third-party vendors with access to consumer data execute written data protection agreements.

9. Staff Training and Oversight

All personnel with access to consumer data receive mandatory training on FCRA obligations, dispute handling procedures, data security protocols, and FDCPA compliance prior to receiving system access. Training is updated annually. A designated Compliance Officer oversees all data furnishing operations and conducts quarterly internal compliance audits.

10. Record Retention

All compliance records, client agreements, dispute resolutions, QA logs, and submission confirmations are retained for a minimum of five to seven years as specified in our Record Retention and Destruction Policy. Records are stored in encrypted, audit-ready cloud storage accessible for immediate bureau review.

11. Consequences of Non-Compliance

Failure to maintain consistent monthly reporting, inaccurate data submission, or failure to respond to consumer disputes within the required timeframe constitutes non-compliance under the FCRA and may result in substantial regulatory penalties, civil liability, and termination of subscriber agreements with consumer reporting agencies. TwelveFold Data Group LLC takes all compliance obligations seriously and maintains zero tolerance for violations of this policy.

12. Policy Review

This policy is reviewed and updated annually by the Compliance Officer and immediately following any material change in regulatory requirements, business operations, or bureau reporting relationships.

13. Contact

For compliance inquiries or to submit a consumer dispute:
TwelveFold Data Group LLC — Compliance Department
30 N Gould St, Ste R
Sheridan, Wyoming 82801
support@twelvefolddata.com
1 (888) 874-2828