For Consumer Reporting Agencies

Runtime FCRA enforcement for consumer reporting agents.

Your screening agents can read the FCRA. They cannot be relied on to apply it to the case in front of them. Kōtsū enforces the controls a CFPB examiner or a plaintiff’s attorney will ask about — in the system, not requested of the model — and proves conformance for every decision.

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The Problem

AI is entering background and tenant screening faster than the FCRA controls around it.

Screening agents now pull the report, match the record to the applicant, and decide adverse action — in employment and tenant screening, where one decision can cost someone a job or a home.

The obligations do not bend for automation. Permissible purpose (§1681b). Maximum possible accuracy (§1681e(b)). The pre-adverse-action step before a consumer is turned down (§1681b(b)(3)). Reinvestigation of a dispute within thirty days (§1681i). When an agent skips one — and narrates its reasoning back as if it had not — the applicant bears the cost, and the agency answers for it to the CFPB, the EEOC, and a plaintiff with a statutory claim.

How Kōtsū works

Four steps. One inline engine.

  1. 01 · Specify

    Your adjudication policy, as a readable specification.

    Your FCRA adjudication matrix, fair-chance rules, and accuracy thresholds — translated from the policy your compliance team already maintains, not invented. Required notices and prohibited actions, both.

  2. 02 · Deploy

    The engine, next to your screening agent.

    Drop-in SDKs and integration paths. The governor runs inline with the agent, across your adjudication and dispute workflows. No rebuild required.

  3. 03 · Govern

    Block the non-conformant action. Require every step.

    Sub-millisecond, rule-based verdicts. An auto-adverse-action that skips the pre-adverse-action notice is blocked before it sends. The agent self-corrects; a person is pulled in only when it can't.

  4. 04 · Certify

    A signed certificate for every file.

    Ed25519-signed, per decision. Proves which FCRA clause permitted each action and that every required notice was issued. The record your examiner — or opposing counsel — asks for.

The proof is the product

Every decision leaves a record that conformed to the FCRA — or it never executed.

Kōtsū emits a cryptographically signed conformance certificate for each file the agent touches. It names the clause that permitted the action, logs the notices that were required and issued, and is verifiable offline by anyone with the public key — no Kōtsū account, no vendor uptime.

CERT      screening-co-2026-06-05-adverse-action-fcra-emp-v1-000142-r0
WORKFLOW  employment-screening-adjudication.yamanote
INPUT     report-000142  (decision: adverse_action)
CLAUSE    §1681b(b)(3) pre-adverse-action  ·  §1681m adverse-action notice
CHECK     pre-adverse-action notice sent + waiting period observed
KEY       SHA256:pEXg1ELa3bFHQnfpNq+MD0+0zrqmTSN4pHzA34Bf2kU
VERDICT   permitted

VERDICT: VALID

Illustrative certificate format. Workflow-specific reference specs are in development with design partners.

Why a new control

Your FCRA program already has controls. None of them is this one.

  • Policy & GRC

    documents what the agent is supposed to do.

  • Audit logging

    records what the agent did.

  • QA sampling

    checks some files, after the fact.

  • Kōtsū

    enforces the FCRA at the moment the agent acts — every file, before the action executes — and signs the proof.

Sampling finds the violation in the files you happened to pull. Kōtsū prevents it in the files you didn't — and gives you per-decision evidence for all of them.

Who Kōtsū is for

Built for the people who answer for the agent’s decisions.

Whether you own FCRA compliance, the screening operation, or the company’s legal exposure — Kōtsū is for you.

Your roleWhat you ownFrameworks you answer toWhere Kōtsū fits
Chief Compliance Officer FCRA conformance and regulator response FCRA, FACTA, CFPB supervision Permissible purpose, accuracy, dispute reinvestigation
General Counsel Litigation and class-action exposure FCRA private right of action, state CRA laws (ICRAA / CCRAA) Adverse-action sequence, willful-noncompliance risk
Head of Screening Operations Adjudication and turnaround EEOC / Title VII, ban-the-box & fair-chance laws Criminal-record adjudication, individualized assessment

Talk to us about enforcing the FCRA on your agents.

The proof is the product. We'd rather show you than tell you.

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