FCRA POLICY – CLARA RISUS, LLC

NMLS 2739485 

Fair Credit Reporting Act (FCRA) Credit Evaluation Policy Effective Date: September 1, 2026 

Clara Risus LLC is committed to making responsible and fair credit decisions while evaluating  each customer as an individual. 

Use of Credit and Payment History 

As part of our credit evaluation process, Clara Risus LLC may use Plaid and other authorized  financial-data or credit-reporting tools to review information relevant to an applicant’s  financial and payment history, when legally permitted and with any required authorization. 

The information reviewed may include payment history, account information, financial history,  and other information relevant to determining a customer’s ability and willingness to meet their  payment obligations. 

Individualized Customer Review 

Clara Risus LLC does not evaluate customers solely by looking at a credit-score number. We  believe a customer is more than a credit score. 

When making a credit decision, Clara Risus LLC may consider the customer’s overall financial  and payment history, available financial information, payment patterns, and other legally  permissible factors. 

A positive payment and credit history may support approval. Negative or insufficient payment or  credit history may result in a denial or other credit terms based on Clara Risus LLC’s established  credit criteria. 

Accuracy and Consumer Rights 

If information obtained from a consumer report or other covered source is used in making an  adverse credit decision, Clara Risus LLC will provide any notices required by applicable federal  and state law. 

Consumers have rights under the Fair Credit Reporting Act (FCRA), including the right to  dispute inaccurate or incomplete information contained in a consumer report.

Clara Risus LLC does not discriminate in credit decisions on any basis prohibited by applicable  law. 

Our Commitment 

Our goal is to make responsible credit decisions while treating every customer fairly and  individually. 

Clara Risus LLC looks at the customer—not just a credit-score number.

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