consumer complaint / dispute

Revised: 12/22/2021

I. Purpose and Scope

Weelo (the "Company") places a high importance on addressing and resolving all consumer complaints in a timely and professional manner.

It is the purpose of this Policy to ensure that the Company complies with applicable federal consumer financial laws in connection with the receipt, tracking, and resolution of any complaints. Specifically, this Policy shall ensure that the Company:

• Investigates, responds to, tracks, and, as appropriate, makes corrections in response to complaints asserted by a consumer or someone acting on their behalf in connection with a Company financial product or service.
• Provides a consumer with accurate and timely information and documents in response to the consumer's requests for information with respect to the Company financial product or service.
• Informs consumers of the appropriate procedures for submitting requests for information or notices of dispute.
• Otherwise complies with applicable legal requirements regarding consumers' complaints or disputes.

The Compliance Department handles all consumer complaints brought against the Company. Each complaint is logged and thoroughly researched, with a response issued in a timely manner. All Company employees are responsible for adherence to this Policy.

II. Definitions

The following definitions shall apply to this Policy:

• Complaint. A Complaint shall include, but not be limited to, any complaint, error resolution notice, or notice of dispute received from a consumer. A Complaint shall also include a complaint received from or via a Company client or third-party vendor.
• Dispute. A Dispute is a type of Complaint that relates to any of the following: (1) the terms of the consumer's account (such as the balance, payment amount, due date); (2) the consumer's performance or other conduct concerning an account (such as current payment status, date, or amount of payment); or (3) other information in a consumer report or credit report that bears on the consumer's creditworthiness.
• Disputed Debt. A Dispute that relates to the consumer's liability for a debt (such as identity theft, fraud) is classified as a Disputed Debt.

III. Legal Background

This Policy has been developed to ensure that the Company's handling of Complaints complies with applicable federal consumer financial laws, including, but not limited to, the Fair Credit Reporting Act, the Fair Debt Collection Practices Act, and the Truth in Lending Act GLBA.

IV. Consumer Complaints

1. Overview

   Responsive and responsible Complaint management is critical to minimizing potential harm to consumers and clients. Complaints may be indicative of a compliance weakness in a Company function, department, or product or service. If handled in a constructive manner, Complaints are an opportunity to improve products and services, enhance customer and client relations, and minimize potential regulatory impact. The Companymust handle all Complaints diligently and resolve these matters promptly and, when applicable, within regulatory requirements.

   The Company communicates directly with consumers for certain financial products and services related to tenant screening processes. As such, consumer Complaints may be received through various means, including via the Weelo App, telephone, in-person contact, social media, email, regulatory agency, and direct written communications. Consumer Complaints may relate to a legal or regulatory matter, financial product or service, or procedure.

   Consumer Complaints should be viewed as an expression of legitimate concern. All Complaints from consumers will be given courteous and fair attention. In many cases, escalation of consumer Complaints can be mitigated by promptly responding with accurate and thorough information at the time of initial communication. Nevertheless, Complaints may need to be escalated for proper handling.

2. Receipt and tracking

   Within five (5) days (excluding Legal Public Holidays, Saturdays, and Sundays) of receipt of a Complaint from a consumer, the Companywill provide the consumer a written response acknowledging receipt of the Complaint. All Complaints must be logged by the Company in its systems within ten (10) business days.

3. Complaint investigation and resolution

   Except as otherwise provided below, the Company must respond to a Complaint within 30 days after receipt of the Complaint by either:

   • Correcting any error(s) identified by the consumer and providing the consumer with written notification of the correction, the effective date of the correction, and contact information (including a telephone number) for further assistance; or
   • Conducting a reasonable investigation and providing the consumer with written notification that includes:
     • a statement that the Company has determined that no error occurred;
     • a statement of the reason(s) for this determination;
     • a statement of the consumer's right to request documents relied upon by the Company in reaching its determination and information regarding how the consumer can request such documents; and
     • contact information (including a telephone number) for further assistance.

   The Company may extend the time period for responding by an additional 15 days if, before the end of the 30-day response period, the Company notifies the consumer, in writing, of the extension and the reasons for the extension.

   If, during its investigation, the Company concludes that errors occurred other than, or in addition to, the error(s) alleged by the consumer, the Company will correct all such additional errors and provide the consumer with a written notification that describes the errors the Company identified, the action taken to correct the error(s), the effective date of the correction, and contact information (including a telephone number) for further assistance.

   The Company may request supporting documentation from a consumer in connection with the investigation of an asserted error but may not :

   • Require a consumer to provide such information as a condition of investigating an asserted error; or
   • Determine that no error occurred because the consumer failed to provide any requested information without conducting a reasonable investigation.

   The Company will provide to the consumer, at no charge, copies of documents and information actually relied upon by the Company in making its determination that no error occurred within 15 days of receiving the consumer's request for such documents. The Company is not required, and will not provide, documents actually relied upon that constitute confidential, proprietary, or privileged information, but will notify the consumer in writing within 15 days of receipt of the consumer's request of its determination to withhold such documentation.

V. Consumer Disputes

1. Overview

   This Section of the Policy applies specifically to Complaints that qualify as Disputes, or notices thereof, submitted by consumers pursuant to the Fair Credit Reporting Act and/or the Fair Debt Collection Practices Act. Consumers may dispute information that the Company furnishes to the credit reporting agencies (CRAs) by notifying either the CRA or the Company directly. Where the Company engages in the business of collecting debts, consumers also may dispute their liability for the alleged debt.

2. Disputes to CRAs

   If a CRA notifies the Company that a consumer disputes information provided by the Company to the CRA, the Company must:

   • Investigate the Dispute and review all relevant information provided by the CRA about the Dispute.
   • Report the Company's findings to the CRA.
   • Provide corrected information to every CRA that received the information if the Company's investigation shows the information is incomplete or inaccurate.
   • Modify the information, delete it, or permanently block its reporting if the information turns out to be inaccurate or incomplete or cannot be verified.

3. Disputes to the Company

   If the Company receives a Dispute directly from a consumer, the Company must investigate the Dispute if it relates to any of the following:

   • The consumer's liability for a credit account or other debt with the Company.
   • The terms of a credit account or other debt with the Company.
   • The consumer's performance or other conduct concerning an account or other relationship with the Company.
   • Any other information in a consumer report about an account or relationship with the Company that affects the consumer's creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or lifestyle.

4. Dispute investigation and resolution

   In response to a notice of Dispute, the Company must do the following:

   • Conduct a reasonable investigation.
   • Review all relevant information provided.
   • Report results to the consumer within 30 days.
   • Notify each CRA to which the Company provided inaccurate information, if the investigation finds the information was inaccurate.

5. Disputed debts

   Where the Company has attempted to collect a debt against a consumer, and the consumer notifies the Company in writing within 30 days that the debt, or any portion thereof, is disputed, the Company must cease collection of the debt, or any disputed portion thereof, until the debt has been validated. To validate the debt, the Company must obtain verification of the debt or a copy of a judgment (or the name and address of the original creditor) and mail to the consumer a copy of such verification or judgment (or name and address of the original creditor).

VI. Frivolous or irrelevant disputes

The Company is not required to investigate Disputes that are frivolous or irrelevant, including in the following situations:

• The consumer did not provide enough information.
• The Dispute is substantially the same as a Dispute previously submitted.
• The Company already fulfilled its obligation and there is no new information.

If a Dispute is found to be frivolous or irrelevant, the Companymust notify the consumer within [five (5)] business days of receiving the notice of Dispute. The Company must include the reason for the determination and, if relevant, any information the consumer needs to submit so that the Company can investigate the disputed information.

VII. Information Requests

This section of the Policy applies to any written request for information that includes the consumer's name, information that allows the Company to identify the consumer's relationship with the Company (including the relevant financial product or service), and the information the consumer is requesting with respect to the relevant financial product or service.

1. Receipt

   Within five (5) days of receiving an information request from a consumer, the Company will provide the consumer with a written response acknowledging receipt of the information request.

2. Response

   The Company must respond to an information request within [30] days of receipt of the information request by either:

   • Providing the consumer with the requested information and contact information (including a telephone number) for further assistance in writing; or
   • Conducting a reasonable search for the requested information and providing the consumer with a written notification that includes:
     • A statement that the Company has determined that the requested information is not available to the Company;
     • A statement of the basis for this determination; and
     • Contact information (including a telephone number) for further assistance.

   For purposes of responding to an information request, information is considered not available if:

   • It is not in the Company's control or possession; or
   • It cannot be retrieved in the ordinary course of business through reasonable efforts.

   The Company may extend the time period for responding to an information request by an additional 15 days if, before the end of the [30]-day response period, the Company notifies the consumer of the extension and the reasons for the extension in writing.

VIII. Training

The Company will provide regular training for all employees to ensure compliance with this Policy. In particular, Company personnel with consumer-facing responsibilities should understand the Company's compliance obligations with respect to consumer complaints and their role in ensuring effective compliance.

IX. Compliance Monitoring and Management Reporting

The Company's Compliance Department should conduct regular reviews of the Company's compliance with this Policy. Internal review or audit findings that report any Policy exceptions should be communicated to the Company's Chief Compliance Officer and if required, to the Company't legal counsel for tracking, correction and remediation.

X. Compliance with Experian's "Reseller Reinvestigation Program Web User Manual"

Weelo has partnered with Experian as part of servicing customers through its tenant screening processes. Experian's manual is attached to this policy and its processes and requirements are incorporated by reference into Weelo's Consumer Compaint Handling Policy. Strict adherence to Experian's Reseller Reinvestigation Program Web Users Manual is mandatory for all employees and contractors who engage in Weelo's complaint handling processes.