Notice to Users of Consumer Reports

Obligations of users under the Fair Credit Reporting Act (FCRA, 15 U.S.C. §1681 et seq.)

The federal Fair Credit Reporting Act requires Communiti.life, PBC ("Communiti"), as a Consumer Reporting Agency, to provide this notice to organizations that obtain consumer reports (background check reports) through the platform. When your organization requests a background check on a volunteer, staff member, or candidate, your organization is a user of a consumer report and has its own legal obligations under the FCRA — separate from Communiti's obligations as the CRA.

Note for volunteer organizations: federal regulators treat the screening of volunteers as a report used for "employment purposes" under the FCRA. All employment-purpose obligations below apply to volunteer screening.

I. Obligations of all users of consumer reports

  • Permissible purpose. You may obtain a consumer report only for a purpose permitted by FCRA §604, and you must certify that purpose to Communiti. On this platform that certification is recorded when you submit a background check request. Obtaining a report under false pretenses is subject to civil and criminal penalties.
  • No other use. The report may be used only for the certified purpose. It may not be shared beyond that purpose or used in violation of any applicable federal or state equal employment opportunity law or regulation.
  • Secure disposal. Records derived from consumer reports must be disposed of securely when no longer needed.

II. Obligations when using reports for employment purposes (including volunteer screening)

  • Before obtaining the report: the subject must receive a clear and conspicuous, standalone written disclosure that a consumer report may be obtained, and must provide written authorization. On this platform, Communiti collects this disclosure and authorization directly from the subject before any check runs — but the legal duty belongs to the user as well.
  • Before taking adverse action (declining to place a volunteer, rescinding an offer, terminating): the subject must receive a copy of the report and the CFPB's Summary of Your Rights Under the Fair Credit Reporting Act, and a reasonable opportunity to respond. Communiti automates this: initiating an adverse action through the platform sends the pre-adverse notice and enforces a five-business-day waiting period.
  • After taking adverse action: the subject must receive an adverse action notice identifying the CRA, stating that the CRA did not make the decision, and describing their rights to dispute and to a free copy of the report. The platform sends this notice when an adverse action is finalized.
  • Do not bypass the platform's adverse action workflow. If your organization decides not to place someone based in whole or in part on a background check report, you must use the platform's adverse action process (or an equivalent FCRA-compliant process of your own) — informal rejection based on a report without the required notices violates the FCRA.

III. Liability

Users who willfully or negligently fail to comply with the FCRA may be liable to the consumer for actual or statutory damages, punitive damages, costs, and attorney's fees (FCRA §§616, 617), and may face enforcement by the FTC, CFPB, and state attorneys general.

IV. Full text

This page summarizes the obligations most relevant to organizations screening volunteers and staff through Communiti. The complete regulatory notice is Appendix N to 12 CFR Part 1022, available from the Consumer Financial Protection Bureau at consumerfinance.gov/learnmore, and the full statute at 15 U.S.C. §1681 et seq.