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Extract to table / memo-regulatory-framework-credit-data.docx
memo-regulatory-framework-credit-data.docx
Parties
HARKNESS LLP
Quorum Insurance Holdings Corp
Strauss LLP
Parties Quorum Insurance Holdings Corp
Ashe LLP
Galloway Nash LLP
Dates
August 8, 2022
June 9, 2023
March 31, 2023
December 31, 2023
October 1, 2020
Amounts
$60,000,000
$4.18
$27.6
$1.42
$100
$1,000
Obligations
Quorum's Intended Uses Quorum has identified the following intended uses for the Meridian data products, each of which must be evaluated against the applicable regulatory requirements: Automated Underwriting Models
This permissible purpose requirement is the central gatekeeping mechanism of the FCRA and imposes obligations on both the CRA (Meridian, which must have reasonable procedures to verify the recipient's permissible purpose) and the recipient (Quorum, which must certify its intended permissible purpose)
The adverse action notice must include, among other things: (i) the name, address, and telephone number of the CRA that furnished the report (i
While these obligations fall primarily on Meridian as the CRA, Quorum must be prepared to cooperate with Meridian in the dispute resolution process when consumers dispute information that Quorum has obtained from Meridian
A covenant providing that if Quorum's commercialization of derived data products (including QuorumScore™) to third parties causes Quorum to become a consumer reporting agency under Section 603(f) of the FCRA, Quorum shall independently assume and bear all CRA compliance obligations with respect to such products, including but not limited to accuracy requirements, consumer disclosure obligations, dispute resolution procedures, and permissible purpose verification for downstream recipients, and shall indemnify Meridian against any claims arising from Quorum's CRA activities
Quorum, as a financial institution receiving substantial volumes of NPI from Meridian, must maintain safeguards appropriate to protect the security and confidentiality of that information