Employment Screening Resources (ESR) founder and CEO Attorney Lester Rosen has written an article — «Complying with the Fair Credit Reporting Act in Four Easy
Steps» — that describes the certification, release and separate disclosure, pre-
adverse action notice, and
adverse action notice requirements
of the FCRA.
The two
steps consist
of a pre-
adverse notice, sent before making a final decision, followed by a notification
of adverse action, sent after a decision not to onboard.