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First half 2nd half 1999 First Half 2nd Half 2000

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Minor Issues

Major Errors

AAA Credit Study #2

"Percentage of major errors and other minor issues that would affect a Consumers Credit Scores"

This data is based on using our AAA Credit Score, which compares data between the three National Credit Repositories. The AAA Credit Score checks for flaws and credit grantor problems within the credit scoring system.

NOTE: Our AAA Credit score cannot check for errors in the consumers credit file in which all three national repositories report the same common credit grantor errors without the help and assistance of the consumer. Those types of errors are not reported in our study.


AAA CREDIT SCORE! Copyright © 2000, allrights reserved

Please be advised that your client: FLINTSTONE, FRED and FLINTSTONE, WILMA (report #49197) is a Candidate for ADVS/CDVS and may have their Fico score Recalculated

The overall AAA Credit Score is: POOR

(excellent, good, fair, poor, fail)

ADVS (B) score is:

CDVS (B) score is:

ADVS (CB) score is:

Copyright ©2000, all rights reserved

91 and is a: A on our "ADVS" grading system.
79 and is a:
79 and is a: C on our "CDVS" grading system.

57 and is a: F on our "ADVS" grading system.

CDVS (CB) score is: 63 and is a: D on our "CDVS" grading system.

The Breakdown between Borrower and Co-Borrower per Bureau for ADVS is as follows:

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The following are reason codes for our AAA Credit Scoring model & ADVS/CDVS grading system:

A: Last reporting dates differ by standard on Rev/Opn

B: Last reporting dates differ by standard on all acct's

C: Known creditors, that effect a consumers Fico scores and meets standard

D: Credit limits on Rev/Opn acct's differ by standard

H: Paying record differs by more than standard and late's within guidelines

J: ECOA codes that meet standard

L: Consumers have BK tradeline and meet standard on trade lines

M: Trade lines show past due status and meet standard

N: Consumers don't show Bankruptcy in PB and differs by standard

Q: Consumers have more file var's than standard

T: Rev/Opn acct's above standard and balance ratio above standard

REMEMBER: Our AAA Credit Score model and ADVS/CDVS grading system does not take into consideration error's that our AAA scoring model can't see or does not know are inaccurate without the help of the consumer. Our scoring model is designed to provide Mortgage Lenders and Consumers a way to check the accuracy of the Fico score and determine what if anything needs to be done on behalf of your consumer. While this score is to be used only as a "GUIDE” only to test the validity of the Fico score. Please keep in mind “WE CAN NOT" predict the final outcome of your consumers Fico score due to “FAIR ISAAC'S" proprietary practices.

Copyright © 2000, all rights reserved



In the Matter of


a limited liability company. File No.


The Federal Trade Commission has conducted an investigation of certain acts and practices of First American CREDCO, Inc. ("CREDCO"), a corporation. On November 30, 1997, CREDCO's consumer reporting business was reorganized as an operating division of First American Real Estate Solutions, LLC, a limited liability company ("First American" or "proposed respondent"). Proposed respondent, having been represented by counsel, is willing to enter into an agreement containing a consent order resolving the allegations contained in the attached draft complaint. Therefore,

IT IS HEREBY AGREED by and between First American Real Estate Solutions, LLC, by its duly authorized officer, and counsel for the Federal Trade Commission that:

1. Proposed respondent is a limited liability company organized under the laws of California, with its principal office or place of business at 150 Second Avenue North, Suite 1600, St. Petersburg, Florida, 33701. 2. Proposed respondent admits all the jurisdictional facts set forth in the draft complaint.

3. Proposed respondent waives:

a. Any further procedural steps;

b. The requirement that the Commission's decision contain a statement of findings of fact and conclusions of law; and

c. All rights to seek judicial review or otherwise to challenge or contest the validity of the order entered pursuant to this agreement.

4. This agreement shall not become part of the public record of the proceeding unless and until it is accepted by the Commission. If this agreement is accepted by the Commission, it, together with the draft complaint, will be placed on the public record for a period of sixty (60) days and information about it publicly released. The Commission thereafter may either withdraw its acceptance of this agreement and so notify proposed respondent, in which event it will take such action as it may consider appropriate, or issue and serve its complaint (in such form as the circumstances may require) and decision in disposition of the proceeding. 5. This agreement is for settlement purposes only and does not constitute an admission by proposed respondent that the law has been violated as alleged in the draft complaint, or that the facts as alleged in the draft complaint, other than the jurisdictional facts, are true. While proposed respondent believes that this agreement and entry of the order are in its interest, proposed respondent specifically denies the allegations of the complaint, other than the jurisdictional facts, and denies that it or CREDCO violated any law as alleged in the complaint or otherwise.

6. This agreement contemplates that, if it is accepted by the Commission, and if such acceptance is not subsequently withdrawn by the Commission pursuant to the provisions of Section 2.34 of the Commission's Rules, the Commission may, without further notice to proposed respondent, (1) issue its complaint corresponding in form and substance with the attached draft complaint and its decision containing the following order in disposition of the proceeding, and (2) make information about it public. When so entered, the order shall have the same force and effect and may be altered, modified, or set aside in the same manner and within the same time provided by statute for other orders. The order shall become final upon service. Delivery of the complaint and the decision and order to proposed respondent by any means specified in Section 4.4 of the Commission's Rules shall constitute service. Proposed respondent waives any right it may have to any other manner of service. The complaint may be used in construing the terms of the order. No agreement, understanding, representation, or interpretation not contained in the order or in the agreement may be used to vary or contradict the terms of the order.

7. Proposed respondent has read the draft complaint and consent order. Proposed respondent understands that it may be liable for civil penalties in the amount provided by law and other appropriate relief for each violation of the order after it becomes final.



For the purposes of this order, the following definitions shall apply:

1. The term "Fair Credit Reporting Act" ("FCRA") refers to the Fair Credit Reporting Act, as amended by Public Law 104-208 (Sept. 30, 1996), 15 U.S.C. §§ 1681-1681u, and as amended in the future.

2. The terms "person," "consumer," "consumer report," "consumer reporting agency," and "file," are defined as set forth in Sections 603(b), (c), (d), (f), and (g), respectively, of the FCRA, 15 U.S.C. §§ 1681a(b), (c), (d), (f) and (g).

3. Unless otherwise specified, "respondent" shall mean First American Real Estate Solutions, LLC, a limited liability company, its successors and assigns, and its officers, agents, representatives, and employees.


IT IS ORDERED that respondent, directly or through any corporation, subsidiary, division, or other device, in connection with the collection, preparation, assembly, maintenance, and furnishing of consumer reports and files, shall comply with Section 611 of the FCRA, 15 U.S.C. § 16811, including but not limited to the following provisions:

A. Subject to Section 611(a)(3), 15 U.S.C. § 1681i(a)(3), if the completeness or accuracy of any item of information contained in a consumer's file at respondent is disputed by the consumer and the consumer notifies respondent directly of such dispute, respondent shall reinvestigate free of charge and record the current status of the disputed information or delete the information from the file, as required by Section 611(a)(1), 15 U.S.C. § 1681i(a)(1);

B. As required by Section 611(a)(2), 15 U.S.C. § 1681i(a)(2), but subject to Section 611(a)(3), 15 U.S.C. § 168li(a)(3),

1. Before the expiration of the five (5)-business-day period beginning on the date on which respondent receives notice of a dispute from a consumer in accordance with Section 611(a)(1), 15 U.S.C. § 1681(a)(1), respondent shall provide notification of the dispute to any person who provided any item of information in dispute, at the address and in the manner established with the person; the notice shall include all relevant information regarding the dispute that respondent has received from the consumer; and

2. Respondent shall promptly provide to the person who provided the information in dispute all relevant information regarding the dispute that is received by respondent from the consumer after the five (5)-business-day period referred to in paragraph B.1. above and before the end of the thirty (30)day period beginning on the date on which respondent receives the notice of the dispute directly from the consumer;

C. As required by Section 611(a)(4), 15 U.S.C. § 1681i(a)(4), in conducting any reinvestigation under Section 611(a)(1), 15 U.S.C. § 1681i(a)(1), with respect to disputed information in the file of any consumer, respondent shall review and consider all relevant information submitted by the consumer in the period described in Section 611(a)(1)(A) with respect to such disputed information;

D. As required by Section 611(a)(5)(C), 15 U.S.C. § 1681i(a)(5)(C), respondent shall maintain reasonable procedures designed to prevent the reappearance in a consumer's file, and in consumer reports on the consumer, of information that has been deleted (other than information that has been reinserted after the person furnishing the information certifies that the information is complete and accurate, as required by Section 611(a)(5)(B)(i), 15 U.S.C. § 1681i(a)(5)(B)(i));

E. Respondent shall provide written notice to the consumer of the results of the reinvestigation of any item disputed by the consumer under Section 611(a), 15 U.S.C. § 1681i(a), not later than five (5) business days after the completion of the reinvestigation of the item, as required by Section 611(a)(6), 15 U.S.C. § 1681i(a)(6), including but not limited to:

1. A notice that the consumer has the right to add a statement to the consumer's file disputing the accuracy or completeness of the information ("dispute statement"), as required by Section 611(a)(6)(B)(iv); and

2. A notice, as required by Section 611(a)(6)(B)(v), that the consumer has the right to request that respondent provide either a notification that the item has been corrected or deleted, or the consumer's dispute statement described in paragraph E.1. above or a codification or summary of that dispute statement, to any person specifically designated by the consumer who has received a consumer report that contained the deleted or disputed information (a) within two years prior to the consumer's request, for employment purposes; or (b) within six months prior to the consumer's request, for any other purpose;

F. If the reinvestigation under Section 611(a), 15 U.S.C. § 1681i(a), does not resolve the consumer's dispute, respondent shall permit the consumer to file a dispute statement, as required by Section 611(b), 15 U.S.C. § 1681i(b);

G. As required by Section 611(c), 15 U.S.C. § 1681i(c), whenever a consumer files a dispute statement pursuant to paragraph I.F. above, respondent shall include the consumer's dispute statement, or a codification or summary of the dispute statement, in all subsequent consumer reports that respondent prepares concerning the consumer that contains the information in question, unless respondent has reasonable grounds to believe the dispute statement is frivolous or irrelevant; and

H. Respondent shall, at the request of the consumer, provide a notification, as required by Section 611(d), 15 U.S.C. § 1681i(d), that a disputed item has been corrected or deleted, or the consumer's dispute statement or a codification or summary of that dispute statement, to any person specifically designated by the consumer who has received a consumer report that contained the deleted or disputed information (a) within two years prior to the consumer's request, for employment purposes; or (b) within six months prior to the consumer's request, for any other purpose.


IT IS FURTHER ORDERED that respondent and its successors and assigns shall for five (5) years maintain and upon request make available to the Federal Trade Commission for inspection and copying all business records demonstrating respondent's compliance with the terms and provisions of this order.


IT IS FURTHER ORDERED that respondent and its successors and assigns shall deliver a copy of this order to all current and future principals, officers, directors, and managers, and to all current and future employees, agents, and representatives having responsibilities with respect to the subject matter of this order, and shall secure from each such person a signed and dated statement acknowledging receipt of the order. Respondent shall deliver this order to such current personnel within thirty (30) days after the date of service of this order, and to such personnel hired after such date within thirty (30) days after the person assumes such position or responsibilities.


IT IS FURTHER ORDERED that respondent and its successors and assigns shall notify the Commission at least thirty (30) days prior to any change in respondent that may affect compliance obligations arising under this order, including but not limited to a dissolution, assignment, sale, merger, or other action that would result in the emergence of a successor entity; the creation or dissolution of a subsidiary, parent, or affiliate that engages in any acts or practices subject to this order; the proposed filing of a bankruptcy petition; or a change in the entity name or address. Provided, however, that, with respect to any proposed change in the entity about which respondent learns less than thirty (30) days prior to the date such action is to take place, respondent shall notify the Commission as soon as is practicable after obtaining such knowledge. All notices required by this Part shall be sent by certified mail to the Associate Director, Division of Enforcement, Bureau of Consumer Protection, Federal Trade Commission, Washington, D.C. 20580.


IT IS FURTHER ORDERED that respondent and its successors and assigns shall, within sixty (60) days after the date of service of this order, and, thereafter, within thirty (30) days of such other times as the Federal Trade Commission may require, file with the Commission a report, in writing, setting forth in detail the manner and form in which it has complied with this order.


This order will terminate twenty (20) years from the date of its issuance, or twenty (20) years from the most recent date that the United States or the Federal Trade Commission files a complaint (with or without an accompanying consent decree) in federal court alleging any violation of the order, whichever comes later; provided, however, that the filing of such a complaint will not affect the duration of: 1. Any Part in this order that terminates in less than twenty (20) years; 2. This order's application to any respondent that is not named as a defendant in such complaint; and 3. This order if such complaint is filed after the order has terminated pursuant to this Part. Provided, further, that if such complaint is dismissed or a federal court rules that the respondent did not violate any provision of the order, and the dismissal or ruling is either not appealed or upheld on appeal, then the order will terminate according to this Part as though the complaint had never been filed, except that the order will not terminate between the date such complaint is filed and the later of the deadline for appealing such dismissal or ruling and the date such dismissal or ruling is upheld on appeal.

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