§§ 1681b(b)(3), 1681i Every subsection, on every file — verified, not assumed

The most rigorous adverse-action compliance file an employer can produce.

Fair-Chance Adverse Action & Screening Compliance Engine assembles a documentation-complete adverse-action file — every statutory notice, the individualized assessment, the 50-state rules engine, the dispute workflow, and the audit trail — checked against FCRA, EEOC guidance, and state Fair-Chance laws before a licensed employment counsel signs off.

Every subsection of FCRA §§ 1681b(b)(3), 1681iEEOC individualized assessment, counsel-signed50-state + 150+ local Fair-Chance rules engineLicensed employment counsel review on every file5-business-day SLA
Why files fail

A single missing notice element can trigger a class action.

An employer's adverse-action decision is only as strong as the compliance file behind it. Miss a standalone disclosure, skip the pre-adverse notice, fail to provide the full report, miscalculate the waiting period, or omit an individualized assessment — and every affected candidate becomes a potential class member with statutory damages of $100–$1,000 per willful violation.

Employers have paid $825M+ in FCRA settlements over five years, and 84% of those settlements trace to defective adverse-action procedures. Most employers run this process manually, from memory, using templates that haven't been updated since the last state law changed. That is exactly where compliance gaps hide.

Fair-Chance Adverse Action & Screening Compliance Engine exists to close that gap with a single, exhaustive standard applied identically to every candidate.

84%
of FCRA settlements involve improper adverse-action procedures
The benchmark

Measured against the letter of the statute — subsection by subsection.

We do not summarize the law and hope. Every file is scored against a versioned rule pack tied to the exact text of FCRA, EEOC guidance, and state Fair-Chance laws. These are the provisions each file is held to.

§1681b(b)(2)(A)

Standalone disclosure

A clear, conspicuous disclosure in a document consisting solely of the disclosure — no liability releases, no extraneous language — that a consumer report may be obtained.

§1681b(b)(3)(A)

Pre-adverse notice

Before taking adverse action, provide the applicant with a copy of the report and a written description of their rights under FCRA.

§1681b(b)(3)(B)

Adverse-action notice

After adverse action, provide notice including the CRA name, address, phone number, a statement that the CRA did not make the decision, and notice of the right to dispute.

EEOC Guidance

Individualized assessment

An EEOC-style assessment considering the nature of the offense, time elapsed, and relevance to the job — conducted and documented before final adverse action.

State Fair-Chance Laws

50-state + local rules engine

Automatically applies the most restrictive jurisdiction's rules on lookback limits, ban-the-box timing, and required notices — updated as laws change.

§1681i

Dispute & reinvestigation

Upon candidate dispute, the FCRA reinvestigation workflow is run correctly and on time, with documented results and a complete audit trail.

How a file is built

Intake to counsel release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A licensed employment counsel signs every release. That order is never reversed.

01

Compliance Gap Scan

Upload your current adverse-action process and a sample report. We return a free compliance read: which statutory elements you already have, and which are missing.

02

Report parsing & rules retrieval

As your authorized compliance agent, we parse the background report, map the offense to the role and work location, and retrieve the controlling FCRA, EEOC, and state/local Fair-Chance rules.

03

Grounded drafting

The disclosure, pre-adverse notice, individualized assessment, and adverse-action notice are drafted from your validated data and the rules engine into field-locked templates — no legal opinions, no invented facts.

04

Deterministic completeness gates

The standalone disclosure is verified to contain no extraneous language; the waiting period is checked against FTC guidance; the individualized assessment addresses all Green factors; any failure blocks release.

05

Counsel review & release

A licensed employment counsel reviews the exception queue and signs the individualized assessment and dispute determinations. High-exposure or novel issues route to senior counsel.

06

Delivery

You receive the file: all notices, the individualized assessment, the rules-applied log, the timing calendar, and the audit trail — ready for the employer to send under its own name.

The bar we hold

Rigor you can measure.

100%
Counsel-signed
No file ships without a licensed employment counsel signature.
5 days
Standard SLA
From complete intake to released file.
<1%
Critical-defect target
Tracked against a gold-standard file library.
50+
Jurisdictions in rules engine
All 50 states + 150+ localities, updated continuously.
Why Fair-Chance Adverse Action & Screening Compliance Engine

Built to be the most thorough option an employer has.

Documentation-complete, by design

The deliverable is completeness itself — every statutory element and rule accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a statutory requirement.

In its lane, on purpose

We prepare documentation and run compliance checks as your clerical agent. We never make the hire/no-hire decision, give legal advice, or contact the candidate.

Engagement

Flat fee per adverse-action case, plus PEPM subscription. No contingency, ever.

Simple, predictable, and aligned with a compliance standard — not a percentage of any settlement or recovery.

  • A free Compliance Gap Scan before you commit — see exactly what is missing.
  • One flat fee per released Adverse Action Compliance File; disclosed pass-through search fees.
  • Per-employee-per-month subscription for the always-compliant workflow and rules engine updates.
  • Optional fixed-fee senior counsel review for high-exposure or novel issues.
FAQ

Questions, answered precisely.

Is Fair-Chance Adverse Action & Screening Compliance Engine a law firm?
No. Fair-Chance Adverse Action & Screening Compliance Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Licensed employment counsel review is available and recommended for all files.
Do you make the hire/no-hire decision?
Never. Fair-Chance Adverse Action & Screening Compliance Engine is not a consumer reporting agency and does not make hiring decisions. The employer retains full decision-making authority; we make the process bulletproof.
What makes a file 'complete'?
Completeness is defined by the statute: the standalone disclosure, pre-adverse notice, individualized assessment, adverse-action notice, dispute workflow, and state/local rule compliance — all present, verified by deterministic gates, and signed by counsel.
How fast is it?
The standard SLA is five business days from complete intake to a counsel-released file. The free Compliance Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released Adverse Action Compliance File, plus a per-employee-per-month subscription for the always-compliant workflow. No contingency and no percentage of any settlement or recovery.

See what's missing before it costs you a class action.

Start with a free Compliance Gap Scan. Send your current adverse-action process and a sample report and we'll return a compliance read against every subsection of FCRA, EEOC guidance, and state Fair-Chance laws.

Documentation-completeness service · not legal advice · the employer sends every notice.