Data Furnisher Policies & Procedures
Fresh Start Data Services LLC maintains written policies and procedures to ensure the accuracy and integrity of all information furnished to consumer reporting agencies, as required by Section 623(e) of the Fair Credit Reporting Act.
Last updated: October 2026
1. Accuracy and Integrity of Information
1.1 Pre-Reporting Verification
Before furnishing any information to a consumer reporting agency (CRA), we verify that all data fields are accurate, complete, and consistent with our internal records. This includes consumer identity information, account status, payment history, and balance data.
1.2 Prohibition on Known Inaccuracies
Pursuant to FCRA § 623(a)(1)(A), we do not furnish any information to a CRA that we know or have reasonable cause to believe is inaccurate. If we discover that previously furnished information is inaccurate, we promptly notify all CRAs to which the information was furnished and provide corrections.
1.3 Metro 2 Format Compliance
All data is furnished in Metro 2® format, the standardized data format published by the Consumer Data Industry Association (CDIA). Each record is validated against Metro 2 field-level rules before submission, including account status codes, payment rating codes, special comment codes, and compliance condition codes.
1.4 Reporting Schedule
We submit a full Metro 2 file to Equifax, Experian, and TransUnion at the end of each monthly billing cycle. Each file includes a Header Record, one Base Segment per active account, applicable supplemental segments (J1, J2, K1–K4, L1, N1), and a Trailer Record with file-level totals.
2. Consumer Dispute Handling
2.1 Bureau-Initiated Disputes (ACDV)
When a CRA notifies us of a consumer dispute via Automated Credit Dispute Verification (ACDV) through the e-OSCAR system, we conduct a reasonable investigation pursuant to FCRA § 623(b). We review all relevant information provided by the CRA, including any documentation submitted by the consumer, and respond within 30 days.
2.2 Direct Consumer Disputes
Pursuant to FCRA § 623(a)(8), consumers may dispute information directly with us. Direct disputes may be submitted through our client portal or by contacting us at the address listed below. We investigate direct disputes within 30 days and notify the consumer of the results.
2.3 Investigation Standards
Our investigation process includes: (a) reviewing all information provided by the CRA or consumer, (b) comparing disputed data against our internal payment records, (c) determining whether the furnished information is accurate, incomplete, or cannot be verified, and (d) reporting the results to the CRA and updating or deleting the information as appropriate.
2.4 Correction and Deletion
If an investigation establishes that furnished information is incomplete or inaccurate, we promptly: (a) modify, delete, or permanently block the reporting of that information, (b) notify all CRAs to which we previously furnished the information, and (c) notify the consumer of the resolution.
3. Data Security
3.1 Encryption
All consumer data is encrypted at rest using AES-256 encryption and in transit using TLS 1.3. Social Security Numbers are used solely for credit bureau registration and are never stored in plaintext.
3.2 Access Controls
Access to consumer data is restricted to authorized personnel on a least-privilege basis. All data access is logged and auditable. Role-based access controls separate administrative, operational, and reporting functions.
3.3 Bureau File Transmission
Metro 2 files are transmitted to each bureau via key-based SFTP (SSH File Transfer Protocol). No consumer data is transmitted via email or unencrypted channels.
3.4 Incident Response
We maintain a written incident response plan for security breaches involving consumer data. In the event of a breach, affected consumers and all applicable regulatory bodies will be notified in accordance with federal and state law.
4. Account Management
4.1 Account Opening
When a consumer enrolls, we verify their identity, register a new trade line with all applicable credit bureaus, and begin reporting payment activity at the end of the first billing cycle.
4.2 Payment Reporting
Payments are reported as on-time (Account Status Code 11) when received within the billing cycle. A grace period is provided before any late payment reporting. Consumers are notified of failed payments immediately and given the opportunity to update their payment method before negative data is furnished.
4.3 Account Closure
When a consumer cancels their subscription, we report the account as closed (Account Status Code 13) to all bureaus. The consumer's payment history remains on their credit file in accordance with standard bureau retention policies (up to 10 years for positive accounts).
4.4 Date of First Delinquency
We accurately report the Date of First Delinquency (DOFD) for any account that becomes delinquent, in compliance with FCRA § 623(a)(5). We do not re-age accounts or manipulate the DOFD. Negative information is removed from reporting after 7 years from the DOFD as required by the 7-year obsolescence rule.
5. Internal Controls
5.1 Quality Assurance
Each Metro 2 file is validated against bureau-grade rules before submission. Validation checks include field format compliance, status code consistency, balance accuracy, and identity data completeness. Files that fail validation are corrected and re-validated before transmission.
5.2 Record Retention
We retain records of all furnished data, dispute investigations, and dispute outcomes for a minimum of 5 years. This includes copies of all Metro 2 files submitted to each bureau, all ACDV responses, and all direct dispute correspondence.
5.3 Policy Updates
These policies and procedures are reviewed and updated at least annually, or more frequently as required by changes in applicable law, regulatory guidance, bureau requirements, or our internal systems.
Contact Information
Entity
Fresh Start Data Services LLC
State of Formation
Florida
Dispute Submissions
Via client portal or /disputes page
Regulatory Framework
FCRA (15 U.S.C. § 1681 et seq.)