When you decline a verification that included a US background check, the Fair Credit Reporting Act (FCRA) imposes a structured set of notice obligations on the operator. The console workflow surfaces compliance reminders at the moment of the decision and dims records that are not reportable under the federal lookback rule.

**This guide explains how the console workflow supports the FCRA-required steps. It is not legal advice.** The platform records your decision and provides the data the FCRA notices reference; the operator is responsible for sending the notices through their own channels. Consult counsel for your specific obligations.

## What FCRA requires

FCRA §615(a) requires a two-step adverse-action notice process when a consumer report contributes to an adverse action against an applicant:

1. **Pre-adverse-action notice**: before taking the adverse action, send the applicant a copy of the consumer report and the "Summary of Your Rights Under the FCRA." Allow a reasonable opportunity to dispute. Operator practice is commonly five business days; the FCRA does not prescribe a specific waiting period.
2. **Post-adverse-action notice**: after taking the adverse action, send a notice that includes the consumer reporting agency's contact information.

Separately, EEOC guidance strongly recommends an **individualized assessment** rather than a blanket exclusion based on the presence of any record, which can create Title VII disparate-impact liability. State law adds further constraints, with several US states capping the reportability of non-conviction records below the federal seven-year ceiling.

## Read a background-check result

Open the applicant in **Dashboard → Applicants**, then open the applicant whose result you want to read. Background-check findings appear in the findings panel alongside any watchlist findings.

Records carry an `fcraReportableInUs` flag derived from the federal FCRA reporting limits: a conviction carries no federal time limit and stays reportable, while a non-conviction record (such as an arrest) is reportable only within the past seven years. Records that are flagged non-reportable are dimmed in the findings panel. Treat the dimmed state as a hint: your applicant's state of residence at the time of the report may impose a stricter rule that excludes additional records the federal flag did not dim.

The reviewer-manual-review guide walks the broader surface; see [Manually review a verification](/guides/verification/reviewer-manual-review) for the decision-panel states.

## Pre-adverse action

Before you click **Decline** in the decision panel, the platform expects the operator to have completed the FCRA pre-adverse step out-of-band. The console does not send the pre-adverse-action notice: that obligation lives with the operator's HRIS, ATS, or notice vendor. Use the applicant detail page as the source of the report contents you reference in your notice.

## Final adverse action

When you do click **Decline** on a verification that carries a `background_us_criminal` or `background_global` check, the decline modal renders the **Compliance reminders for background-check declines** panel above the decision buttons. The panel is collapsed by default; expand it to read the four notices:

- **Individualized assessment**: the EEOC-recommended practice of evaluating the record case by case.
- **State-specific lookback caps**: the reminder that several states cap reportability below the federal rule.
- **Adverse action notice obligation**: the two-step §615(a) summary.
- **Data protection notice**: the sensitive-PII handling reminder.

The reminder panel is text-only: there is no acknowledgment checkbox and no audit event when you open it. The decline still requires you to cite at least one finding or one triggered rule; a notes-only decline is not accepted.

## Document the decision

When you submit the decline, the reviewer-decision write captures:

- The reason code you selected from the dropdown.
- Every cited finding id and every cited rule id.
- Your free-form notes: use this field to record the individualized assessment you ran (job-relatedness, age of conviction, evidence of rehabilitation).
- Your reviewer identity and the wall-clock timestamp.

The write emits a `kyc.session.reviewer_declined` audit-log row through the HMAC-chained writer. The cited findings are linked from the row so a forensic walkthrough can reproduce the evidence you decided on.

## Common questions

If a finding you expected to dim is not dimmed, the federal rule still considers it reportable, and you may need to apply a stricter state rule yourself. The platform does not suppress records by jurisdiction; apply state-specific rules during your review.

If a verification was declined and you are walking back to understand why, see the [verification-declined FAQ](/guides/faq/verification-declined). For terminology, see the [Glossary](/glossary).