Training & ResourcesPolicy Handbook
What You Need At Your Fingertips
What You Need At Your Fingertips
KW Dallas Metro North
A guide to Market Center policies
Notice to Broker & Sales Associates
Any of a Sales or Broker Associate’s actions that violate the provisions of this Policy and Associate Handbook or the Keller Williams Realty International Policies and Guidelines Manual are unauthorized and outside the authority of the Sponsoring Broker-Sales and Broker Associate relationship. All expense or loss arising out of a Sales or Broker Associate’s acts shall be borne solely by the Sales or Broker Associate. All expenses or losses suffered by a Sponsoring Broker as a result of a Sales or Broker Associate’s acts shall be reimbursed by the Sales or Broker Associate. Any waiver of this provision by the Sponsoring Broker with respect to any actions will not be construed as a waiver with respect to any other action.
All Sales and Broker Associates are required to review, understand and follow the full Keller Williams Policies and Guidelines Manual. To access the Keller Williams Policies and Guidelines Manual:
- Log onto www.mykw.kw.com.
- Click on the Resources tab
- Click on IALC & PG Manual
- Click to open the Policy Guidelines Manual
Keller Williams Realty is committed to providing a work environment that is free from discrimination. In keeping with this commitment, Keller Williams Realty maintains a strict policy prohibiting unlawful harassment of employees and associates both by supervisory and non-supervisory individuals. Furthermore, we prohibit harassment in any form, including verbal, physical and visual harassment.
To review the full policy and reporting procedures, refer to the KWRI Policies & Guidelines Manual, Section 4, 188.8.131.52 Harassment Policy and 184.108.40.206 Harassment Reporting.
Statement of Policy RESPA
It is the policy of the Dallas Metro North Market Center of Keller Williams Realty that the Market Center and all of its agents shall comply in all respects with applicable law. This policy continues in full force.
In particular, the Market Center wishes to direct the attention of all of its agents to the Real Estate Settlement Procedures Act, commonly known as “RESPA”. RESPA provides in part that:
“No person shall give and no person shall receive any fee, kickback or thing of value pursuant to any agreement or understanding, oral or otherwise, that the business incident to or a part of any real estate settlement service involving a federally related mortgage loan shall be referred to any person.”
RESPA is administered by the U.S. Department of Housing and Urban Development. (HUD) The Market Center has been advised that the HUD takes the position that accepting anything of value from a party providing settlement services (such as a title company) when that party expects to obtain referrals is a violation of RESPA.
It is the Market Center’s policy that none of its agents engage in conduct in violation of RESPA.
Our Market Center provides a list of Red Carpet vendors for our agent’s convenience. As an Independent Contractor, you and your clients may choose to use any vendor of your choice not limited to any vendor on our Red Carpet List. We do not promise nor do we provide these Red Carpet vendors any direct leads for business. Red Carpet vendors are provided advertising/marketing opportunities only.
Policy & Procedure for Buying and Selling Agents’ Personal Property
Dallas Metro North market center agents are able to list their own personal property for sale.
On July 8, 2009, the 2009 ALC voted for the following policy regarding agent/owned properties:
*Agents shall have the option of listing property for sale in which they hold ownership only under a specific set of guidelines. The agent must have been a licensed Realtor for at least a 2-year period, and must obtain approval from the Team Leader to list. Less experienced agents will need to work with a more experienced agent on the sale of their own property. Upon approval, any agent that lists properties in which they have ownership must, without exception, have the following documents prior to closing:
- Under NO circumstances can the agent represent the buyer and cannot be an Intermediary without appointments in the sale of their own property. The buyer must have their own representation.
- Ownership is defined as owning at least 10% of the property
- All forms must be state approved with full & accurate signatures & dates
- A completed Seller’s Disclosure notice must have all signatures, dates & initials
- A home inspection must be performed and a copy of the inspection, along with all addendum and/or amendments must be part of the file
- A home warranty must be purchased for the new owner
- The property must have been agent/owned for 180 days to avoid flipping
- Agent is allowed to sell one personal residence per 12 month period with 0% commission taken with market center approval
- Ownership must be disclosed in all marketing materials, MLS, advertising & stated in the contract, Pg. 1, #4 (License Holder Disclosure).
- Buyer must sign an agency representation disclosure (IABS).
Per the Dallas Metro North’s franchise agreement with Keller Williams International, you are allowed to purchase one home per year taking 0% commission. This transaction must be for your personal use and not for investment, and your name must appear on the contract as the purchaser. This does not apply to relatives or friends.
If you choose to take a commission on the personal purchase, you will not have to pay Company Dollar but you will be responsible for the 6% Royalty Fee per KWRI. The market center will be charged royalty, therefore the agent must pay royalty.
Agent is required to turn in a copy of the HUD-1 and copies of any commission checks
In the event of a lawsuit involving an agent-owned property, the owner/agent will be responsible for the entire deductible amount.
Dallas Metro North market center agents are able to list and purchase their own personal investment properties for sale. On December 14, 2016, the 2016 ALC voted for the following policy regarding agent/owned Investment Properties:
Agent must collect a minimum of 1% of sales price as commission.
Sample Disclosure for Agents
Making Purchases in Their Name, or LLC of which they own 10% or more. To be used when property is NOT in the MLS and/or the seller is NOT represented.
This is a sample only, and we highly recommend that you have an attorney create a document, or a statement for special provisions that addresses these issues with complete transparency.
If you create an agreement/disclosure similar to this, you will want to assure it has full signatures of all sellers, and use Paragraph 22 on the TREC contract to include the agreement/disclosure as a part of the contract.
It is your responsibility to read this thoroughly and carefully, to consider only the phrases which are appropriate to your transaction, and to get your own legal representation when purchasing a property either as an owner occupant, or as an investor. This is intended only to help you understand the issues that arise as a Licensed Realtor purchaser.
- Licensee. You acknowledge that a real estate license holder is a party to this transaction (the Buyer), or acting on behalf of a spouse, parent, child, business entity in which the license holder owns more than 10%, or a trust for which the license holder acts as a trustee or of which the license holder or the license holder’s spouse, parent or child is a beneficiary.
- Multiple Listing Service. You have been informed that it is likely you would receive a higher sales price and maximum exposure for your home through the use of a traditional listing agreement, a listing on MLS and a longer marketing period. It is a certainty that you would reach a larger pool of potential buyers by listing in MLS.
- Sales Price. You acknowledge and agree that you have been given the opportunity to review relevant property sales information and a Comparative Market Analysis. The Sales Price may be below what may be considered as ‘fair market value’ and by entering into this Contract you are agreeing to accept the Sales Price, less Deductions, which could result in net proceeds to you which may be below what may be considered as ‘fair market value’. You acknowledge that this Sales Contract may result in less net cash proceeds to you at Closing, if any, than you may have been able to obtain from another third-party buyer had you not entered into this Contract, and you hereby waive and release Buyer Parties from any claims to the contrary.
- Right to Representation. Further, you hereby acknowledge and agree that the Sales Price, and all terms and conditions, have been fully negotiated between you and Buyer, and that prior to executing this Contract, you have had a full opportunity to speak with, retain, consult, or solicit the services from persons or entities, attorneys, real estate brokers, professionals or otherwise, of your own choosing with respect to the decision to enter into this Contract, and to the extent you did not avail yourself of such opportunity, you do so at your sole risk.
- Disclosures. You acknowledge that the Buyer in this transaction is associated with Keller Williams Realty, a licensed Real Estate Broker in the State of Texas. You also acknowledge that the Buyer, the Buyer’s Broker and other related parties may share common ownership interests or be affiliated with certain third-parties who perform services in connection with this Sale Contract or the listing or purchase of the Property, including without limitation, the escrow agent, title company, or contractors or other service providers who may perform services or repairs on the Property.
DMN’s Capping Policies
- $18,000 cap for all individual agents, rainmakers. Husband/wife share one cap. Agents are on a 80/20 split with Market Center until cap is reached.
- Licensed assistants do not have a cap and pay only KWRI monthly expenses as office bill.
- $4,500 Buyer Agent cap ($9,000 buyer agent cap for first full year on team if from within Market Center, then reverts to $4,500 for the following years). Buyers agents split with team first and then their portion is on an 85/15 split with Market Center until their cap is reached. For Market Center purposes, all leads and all clients belong 100% to the lead agent/rainmaker, regardless of origin. All listings will be in the name of lead agent/rainmaker on MLS.
- Partnership Cap Structure = Add $18,000 cap plus $4,500 (or $9,000 if from within Market Center) Buyer Agent cap together for a total cap of $22,500 (or $27,000 Year 1). Partners must operate with joint logo, joint marketing, DBA with TREC. Partners should share expenses and income and behave as one single entity for business purposes. Team leader approval required for partnerships. Income shall be split 50/50 per transaction; or partners shall sign a guarantee of the full cap amount; or partners will form an LLC which becomes the licensed entity and all transactions occur against the partnership total cap and Market Center will pay all commissions to LLC. Partnerships have all transaction on a 80/20 split with Market Center until capping.
Visiting Vendor Policy
At Keller Williams Dallas Metro North, we are proactive in protecting the safety, privacy and professionalism of our agents. Keller Williams Dallas Metro North supports our agents as independent business professionals and places a high value on the agents’ ability to create and maintain relationships with vendors of their choice. We also want to assure our agents’ ability to come into the office and work safely, privately, and without interruption.
Therefore, the Agent Leadership Council and staff of Keller Williams Dallas Metro North have established the following policy regarding office visitations by vendors and vendor representatives. The purpose is to maintain a welcoming office but to confirm that the ability to enter into private agent offices and shared workspaces is a granted privilege, not a right.
- All vendors must enter through the front door and check-in with the front desk personnel. There will be no exceptions.
- If vendors have an appointment with a specific agent, that agent will be contacted and with the agent’s permission, the vendor will be allowed to proceed to the agent’s office. If the agent is not in the building, the vendor will be invited to leave communication with front desk personnel, which will be passed to the agent as promptly as possible.
- Due to the sensitive information held in transaction files, vendor representatives must go promptly to the office of the appointed agent and are not invited to linger in any common areas without the accompaniment of a Keller Williams agent.
- Promotional materials of event announcements will be distributed only through front desk personnel and may not be left in private office areas or shared workspaces without staff approval.
- Any events, promotions of marketing initiatives requiring an exception to this policy must be approved by the Team Leader or designee, in writing, at least 48 hours in advance, so that front desk personnel can be notified. Should any vendor desire further access to agents, they should contact Team Leader Stacey Buettner or her designee, (firstname.lastname@example.org or email@example.com ), with their specific proposal with as much advance notice as possible and await approval through the staff and Agent Leadership Council. As is customary in our industry, Keller Williams Dallas Metro North has advertising partners and preferred vendor relationships in place and we will honor those to the best of our ability, without interfering in our agents’ desire to maintain business relationships of their own.
- All vendors visiting the market center are expected to comply with the spirit and intent of this policy. All vendors are expected to behave professionally at all times while on the grounds of Keller Williams Dallas Metro North.
Property Management Policy
Engaging in property management has become one of the largest potential areas of risk we face in our industry and our company. Laws have changed and property management may no longer be conducted through Keller Williams Dallas Metro North without the consent and participation of the Team Leader/Broker. Property management must now be considered a primary business rather than a sideline and for this reason, strict guidelines have been placed on Independent Contractors who engage in this high risk area of real estate.
Dallas Metro North will offer our agents two options to choose from when participating in Property Management. Both option require the following:
1.Agent must have been licensed and in the practice of real estate for a minimum of 2 years, or receive Team Leader/Broker permission due to other relevant factors.
2.Any individual who controls the acceptance or depost of rent for a single family residence must have a real estate license.
3.Agent must hold the designation of Certified Property Manager (CPM) or better, or can prove they are currently working towards a property management designation.
4.Agent must meet with the Team Leader or designee to present their written “Property Management” business plan.
5.Agent must agree and provide open access to all property management files.
6.Experienced agents joining Keller Williams Realty with a property management business will be subject to review and will be required to follow all appropriate policies.
Option 1- Agent chooses to operate their property management business under Keller Williams Dallas Metro North:
1.Agent must provide copies of:
All active property management agreements showing compliance with the approved template
Copy of all property management trust accounts showing our sponsoring Broker on the record
- Agent will be responsible to 100% of the deductible in the event of a property management related claim and 100% of any legal fees or settlement fees outside of a claim.
- Agent agrees to submit a copy of all property management agreements entered into by agent of designee assigned by the Team Leader. In addition, agent agrees to pay a flat fee of $15 for each submitted agreement (to be added to the next generated office bill). Agent understands that this flat fee is not calculated toward Agent’s cap to KWRI or to Dallas Metro North. Agents E & O insurance fee will be the same as all other producing agents (no additional increase due to property management activities).
Option 2 – Agents may choose to create an LLC, register the LLC with TREC and operate their property management business totally separate from Keller Williams Dallas Metro North.
1.Agents must research this option and abide by all TREC rules and regulations, which include that a licensed Broker must be a principle in the LLC and be authorized to sign on all bank accounts. For those agents who are themselves licensed Brokers in the state of Texas, this should satisfy that requirement.
2.Agents will be required to sign an agreement (Attachment 1) stating that their property management business will not be handled through Keller Williams Dallas Metro North and not covered by our available E & O coverage, but by their property management business.
3.Agents must not refer to Keller Williams Dallas Metro North and must clearly indicate that their property management business is not part of our office and they must include the attached language (Attachment 2) in all of their Residential Leasing and Property Management Agreements and their Residential Lease Agreements Special Provisions.
4.They must not meet Tenants or Landlords at the Keller Williams offices or allow Tenants or Landlords to drop off contracts of payments at the Keller Williams offices.
5.Note that all residential or commercial seller, landlord, buyer or tenant representation agreements that involve use of MLS shall be conducted through Keller Williams Dallas Metro North and will be subject to the agent’s capping structure. Only the ongoing property management responsibilities shall be conducted outside of Keller Williams Dallas Metro North.
Texas Real Estate Licensing Act reference:
1.Commission Rule 535.146(a) requires that a broker maintain a separate account for funds held in trust. Further Commission Rule 535.146(b) instructs that a broker may designate a salesperson as an authorized signatory on any trust account; however, the broker shall be solely responsible and accountable for all trust funds received by the broker and all deposits and/or disbursements from the trust account.
2.If the duties include showing or leasing the property for the owner for which the manager gets paid, a license would be required. See Rule 535.13(b). Also, beginning September 1, 2011, a license will be required for any person who controls the acceptance or deposit or rent from a resident of a single-family residential real property unit. [TRELA §1101.002.(1)(A)(x)]
I agree to abide by the above policy regarding property management. Failure to do so on my behalf will result in the immediate withdrawal of Market Center Approval and all Property Management accounts will be transferred to another Independent Contractor of Team Leaders choice within the Market Center.
I intend to:
_____ Not participate in property management activities
_____ Operate a property management business under Keller Williams Dallas Metro North
_____ Operate a separate registered LLC property management business
Independent Contractor (print) Independent Contractor Signature & Date
TREC Guidelines for Using Unlicensed Assistants
Unlicensed Assistants Shall:
1) Act as a courier in delivering documents, picking up keys, or similar services.
2) Perform clerical duties such as typing, answering the telephone, forwarding calls, and scheduling appointments for licensees.
3) Submit forms and changes to multiple listing services. Obtain status reports on loan progress and credit reports, etc.
4) Follow-up on loan commitments after a contract has been negotiated; and pick up and deliver loan documents.
5) Obtain public information from sources like government offices, utility companies, title companies, etc.
6) Write and place advertising with licensee proofing and approval.
7) Make keys, install lock boxes, and place/remove signs on property.
8) Gather information for comparative market analysis.
9) Transport people to properties and/or around areas of interest but may NOT show, answer questions, or interpret information regarding property, price or condition.
10) Perform accounting and collection functions such as collecting rents, recording and depositing earnest moneys, security deposits, rental funds and/or computing commission checks.
11) Order or perform items of repair and/or maintenance.
12) Provide information pertaining to the characteristics of real estate or a business opportunity and the terms or the conditions of a transaction only if that information is prepared in writing and approved in advance by a licensee.
Unlicensed Assistant Shall Not:
1) Engage in activity for which a real estate license is required.
2) Engage in any conduct which is “used, designed or structured” to procure prospects.
3) Show properties, answer questions, or interpret information regarding property, price or condition. Unlicensed Assistants cannot open doors, allow access to a property or host an Open House.
4) Interpret information regarding listings, titles, financing, contracts, closings or other information relating to a transaction.
5) Conduct telemarketing or telephone canvassing to schedule appointments in order to seek clients.
6) Fill in legal forms or negotiate price and/or terms.
7) Perform any act with intent to circumvent or which results in the circumvention of the real estate licensing law.
Policy and Etiquette for Use of Online Communities (Social Networking)
Sackbornh, LLC dba Keller Williams Realty Dallas Metro North (Company) reserves the right to suspend or terminate association with anyone (Independent Contractor or staff personnel) who engages in the use of online communities and violates this policy. This policy applies to the use of any Online Community in which the agent or staff person affiliates themselves with the Company (you put your name and the Company name on the site).
Linkedin, Facebook, Bebo, Plaxo, Naymz, Spoke, Experteer, Xing, Twitter, Friend Reunited are examples of types of Online Communities or Social Networking.
By joining and using these online communities, you agree that you have read and will follow the rules and guidelines set for these peer discussion groups. You also agree to reserve list discussions for topics best suited to the medium. This is a great medium with which to solicit the advice of your peers, benefits from their experience, generate leads, and participate in an ongoing conversation.
*Don’t challenge or attack others. Community discussions are meant to stimulate conversation, not to create contention. Let others have their say, just as you may.
*Don’t post Commercial Messages on any online learning community. Contact people directly with product and service information if you believe it would help them.
*Use caution when discussing products. Information posted on the lists are available for all to see, and comments are subject to libel, slander, and antitrust laws.
*All defamatory, abusive, profane, threatening, offensive, pornographic, or illegal materials are strictly prohibited. Do not post anything in an online community message that you would not want the world to see or that you would not want anyone to know came from you.
*Do not use copyrighted materials.
*Remember that most learning community participants have the right to reproduce postings.
*Send your message only to the most appropriate communities. Do not spam community participants.
*Keep discussion comments positive and productive. Derogatory comments and statements; vulgar or offensive comments are unacceptable.
*State concisely and clearly the topic when posting comments on a new discussion.
*Use caution when accepting friends into your site, the material they have must conform to this policy.
*All use of your online communities must conform to Texas Real Estate Commission statutes and rules and the National Association of Realtors Code of Ethics.
The Company does not actively monitor online communities for inappropriate postings.
However, this policy will be strictly enforced if an agent is found to be in violation.
The goal of the hospitalization policy is to establish a guideline for support after a hospital stay.
This policy provides assistance for an agent who must stay in the hospital for illness and/or surgical reasons. Upon release, the agent may be home-bound for some time and should not feel isolated.
A gift of meals and/or food can be provided at home to the agent during the recovery period with a value up to $80.
The goal of the bereavement policy is to establish a network of assistance during the time of an agent loss. The KW Cares Committee shall handle each occurrence with kindness, giving help where needed, but not to overwhelm.
The bereaving agent shall contact either the Team Leader or Agent Services, preferably by text message or email.
Depending on the agent need, one or both of these steps will then be taken –
A prayer chain will begin
A care calendar will be set up
A member of the KW Cares Committee will be in charge of setting up the prayer chain, and if needed, a care calendar. This person will communicate to the market center the family needs via email.
Each bereavement situation is unique and should be handled so.
KWDMN Cares Fund Guidelines for a Monetary Gift/Loan
An unforeseen, life changing sudden event to a colleague or their immediate family member. Examples – medical diagnosis, fire, car wreck, etc.
May be a grant or a loan. If a loan, the recipient agrees to sign a repayment schedule.
Distribution amount to be at the sole discretion of the Team Leader.
Annual Cap Distribution – $750.00
Been a member of the office for a minimum of 2 months – maximum distribution $100
Been a member of the office 2-4 months – maximum distribution $200
Been a member of the office 4-7 months – maximum distribution $400
Been a member of the office 7-12 months – maximum distribution $500
All recipients must sign a Non-Disclosure Agreement
Any recipient receiving over $500 must agree to join coaching
Agent/recipient agrees to sign a repayment schedule
May be a loan or a grant
MCA is to add the loan to the recipient’s office bill
1) The Fair and Accurate Credit Transactions Act of 2003 (FACTA) and subsequent revisions and the FTC rules adopted under that act.
2) Sections 35.48, 35.581 and 35.62 of the U.S. Business and Commerce code
1) How is personal information collected?
2) How and when is the personal information used?
3) How is the personal information protected?
4) Who has access to the personal information?
5 )How is the personal information disposed?
- Definition of personal information.
- Information in a consumer report*; or
- An individual’s first name or initial and last name in a combination with any of the following:
1) Birth date
2) Social security number or other government issued ID number
3) Mother’s maiden name
4) Unique biometric data (fingerprint, voice print, retina image);
5) Unique electronic ID number of routing code:
6) Telecommunication access devices including debit or credit card info;
7) Financial institution account or information
*Note: A consumer report is a report related to a person’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living prepared by or obtained from an agency that collects such information such as a credit reporting agency.
- The collection of personal information
The Company collects personal information in the following ways:
1) In consumer reports relating to lease applications or for other
reasons the consumer may authorize the Company to obtain;
2) In other real estate related forms the customer or client completes or is related to a transaction such as an earnest money or option fee check;
3) In lease applications a prospective tenant completes;
4) In tax reporting forms that the customer or client is required to complete and which are given to the Company.
III. The Use of Personal Information
Personal Information from Clients and Customers: When the Company represents a client (buyer, seller, landlord or tenant) in a transaction, the agent servicing the client may come into possession of personal information of the client as is customary and appropriate to facilitate the transaction. The most common personal information collected in a real estate transaction are in the form of checks for payment of items such as earnest money, option fees or payment for some item in the transaction.
Personal Information from Prospective Tenants: The personal information
that prospective tenants provide to the Company is primarily used to obtain
consumer reports (credit checks). It may also be used to perform background
checks and rental history searches. The information in the consumer reports may be discussed with landlords for whom the Company manages property. The Company also reports information to credit reporting agencies and uses
personal information to complete those reports.
Personal Information from Owners of Properties Managed by the Company;
When the Company acts as a property manager for a property owner, the
Company uses the property owner’s personal information only: (a) to deliver
the required management services; (b) to file any required reports with
government agencies (for example, the IRS); or (c) for other purposes the
property owner may authorize.
- Protection of Personal Information
Written files in this Company are protected under lock and key or an otherwise
secure manner under prudent security practices.
Electronic records are under an access name, password protected, and are assigned to appropriate persons in the Company.
The Company and its agents exercise reasonable discretion when discussing
any personal information with others and releases personal information to
others only as described by this policy.
This Company does not permit its employees or agents to make copies of
consumer reports or records of insurance claims. The consumer reports in
the Company files are not to be accessed in the future and are retained as a
convenience to customers or clients.
The individual agents that work with this Company are independent contractors and the agent with who a customer of client works with may maintain a separate transaction file. The Company instructs its agents to not permit other persons to access the personal information in files the agents maintain. The Company instructs its agents to protect the personal information in the agents’ files in the same manner as prescribed in this policy.
- Access to the Personal Information
The following persons have access to personal information in this Company’s files:
(1) The agent and or broker who is servicing or coordinating the transaction
(2) Appropriate staff personnel of the Company as necessary to service the
agent, client or customer in the transaction
(3) Owner’s of the Company as is necessary in their duties
(4) The Team Leaders of the Company servicing the agents
Property owners for who the Company manages properties do not have access
to personal information in the Company’s files. However, the Company and its
agents may discuss the information in a tenant’s consumer report or lease
application with a property owner. Copies of such information are provided to the
landlord only: (1) with the tenant’s consent; or (2) if the Company ceases to be
the property manager and the landlord requests that the files be sent to the
landlord, the landlord’s attorney, or the new property manager.
Personal information from a buyer, seller, landlord, or tenant may be discussed
with others (such as mortgage lenders or prospective landlords) only as is reasonably necessary to negotiate or close the transaction in order to provide the services the customer or client seeks from this company.
This Company may, at the customer’s or clients’ request, provide personal information to service providers in a transaction such as a title company or mortgage company if it is necessary to expedite or complete a transaction.
If the Company is required by law to allow others to access the personal information in the Company’s files, the Company will comply with the law (for example, compliance with court orders, subpoenas, or governmental investigations). The Company will also allow law enforcement agencies access to personal information in order to cooperate with such investigations.
VI Disposal of personal information:
The company uses reasonable measures to dispose of personal information. Personal information is usually disposed of by shredding or burning documents utilizing a professional document and record destruction company. Electronic files are erased by means that make the files unreadable or undecipherable, or by eradicating personal information from documents or electronic files in ways that make the personal information unreadable.
VII Erroneous Records:
If the Company erroneously reports information to a consumer reporting agency, the Company will act to correct the information in the Company’s records and request the reporting agency to correct the information in its records promptly after the Company has learned and determined the report was in error.
If the Company maintains an erroneous record that a consumer has issued a dishonored check, the Company will promptly delete the record after the Company receives from the consumer that the information is in error or after the consumer provides the Company with a law enforcement agency report stating the dishonored check was not authorized.
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